#523_2019_1107_TH_FINAL

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
523
Laboratory Name:
Mt. Olive Pickle Co. WWTP
Inspection Type:
Municipal Maintenance
Inspector Name(s):
Tom Halvosa, Todd Crawford
Inspection Date:
11/7/2019
Date Forwarded for Initial
Review:
11/26/2019
Initial Review by:
JMS
Date Initial Review
Completed:
11/26/2019
Cover Letter to use:
❑ Insp. Initial
❑Insp. No Finding
❑Corrected
® Insp. Reg
❑Insp. CP
❑Insp. Reg. Delay
Unit Supervisor/Chemist III:
Todd Crawford
Date Received:
12/3/2019
Date Forwarded to Admin.:
12/16/2019
Date Mailed:
12/30/2019
Special Mailing Instructions:
Send a copy to Robbie Bullock at the WaRO.

OY COOPER
LINDA CULPEPPER
Environme"fW Quality
December 30, 2019
523
Mr. Kevin Campbell
Mt. Olive Pickle Co. WWTP
P.O. Box 609
Mt. Olive, NC 28365
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Campbell:
Enclosed is a report for the inspection performed on November 7, 2019 by Tom Halvosa. 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. 251.
Sincerely,
Todd Crawford
Technical Assistance & Compliance Specialist
NC WW/GW Laboratory Certification Branch
Attachment
cc: Tom Halvosa, Dana Satterwhite
North Carolina Department of Environmental Quality I Division of Water Resources
1623 Mail Service Center I Raleigh, North Carolina 27699-1623
Phone [phone]/Fax 91-9.733,6241

LABORATORY NAME: Mt. Olive Pickle Co. WWTP
NPDES PERMIT : NC0001074
ADDRESS: 1 Cucumber Blvd
Mt. Olive, NC 28365
CERTIFICATE #: 523
DATE OF INSPECTION: November 7, 2019
TYPE OF INSPECTION Municipal Maintenance
AUDITOR(S): Tom Halvosa and Todd Crawford
LOCAL PERSON(S) CONTACTED: Kevin Campbell and Garrett Hatsell
This laboratory was inspected by representatives 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:
This inspection was requested by the Supervisor of the laboratory, Kevin Campbell. They had not
been inspected since 2009 and he wanted to make sure they were performing analyses according
to current regulations and requirements. Staff were forthcoming and seemed eager to adopt
necessary changes.
All required Proficiency Testing (PT) Samples have been analyzed and the laboratory has fulfilled
its PT requirements for the 2019 PT Calendar Year.
The laboratory submitted their Quality Assurance (QA) and/or Standard Operating Procedure
(SOP) document(s) in advance of the inspection. These documents were reviewed and editorial
and substantive revision requirements and 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 November 30, 2020.
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

#523 Mt. Olive Pickle Co. WWTP
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".
Laboratory Fortified Matrix (LFM) and Laboratory Fortified Matrix Duplicate (LFMD) are also
known as Matrix Spike (MS) and Matrix Spike Duplicate (MSD) and may be used
interchangeably in this report.
Contracted analyses are performed by Environmental Chemists, Inc. (Certification 94).
Approved Procedure documents for the analysis of the facility's currently certified Field
Parameters were provided at the time of the inspection.
- - c - ,,_.
1 1,
Analytical Balance
A. Finding: The analytical balance level indicator bubble was outside the circle of accepted
range.
Requirement: Always check that the air bubble is in the center of the level indicator
before each weighing. Use the leveling feet to make adjustments. Once leveled, always
perform an internal adjustment. The exact procedure is described in the operating
instructions for the balance. Ref: Mettler Toledo, Weighing the Right Way, January
2015, Section 3.
Recommendation: It is recommended that the laboratory document on their
Suspended Residue benchsheet that the analytical balance level indicator bubble is
inside the circle of accepted range during each use.
B. Finding: The laboratory is not checking the analytical balance each day used.
Requirement: The analytical balance shall be checked with one ASTM Type 1, Class 1
or 2, or equivalent standard weight each day used. Ref: 15A NCAC 2H .0805 (a) (7) (J).
Equipment
C. Finding: The desiccant in the desiccator is exhausted.
Requirement: Each facility shall contain or be equipped with the following: Glassware,
chemicals, supplies, and equipment required to perform all tests, analyses,
measurements, or monitoring included in its Certification. Ref: 15A NCAC 02H .0805
(a) (6) (B)•
Requirement: Desiccator, provided with a desiccant containing a color indicator of
moisture concentration or an instrumental indicator. Ref: Standard Methods, 2540 13-
2011 (2) (d).

#523 Mt. Olive Pickle Co. WWTP
Comment: The desiccant in the desiccator was pink' colored indicating the need for
replacement or regeneration.
Documentation
D. Finding: The laboratory is not documenting the temperature of the Biological Oxygen
Demand (BOD) incubator or consistently documenting the temperature of the residue
oven.
Requirement: Incubate at 20°C ± 1 °C the stoppered and sealed BOD bottles containing
desired dilutions (¶ a above), seed controls (5210B,6d), dilution water blanks
(5210B.6c), and glucose-glutamic acid checks (5210B.6b). Exclude light to avoid growth
of algae in the bottles during incubation. Ref: Standard Methods, 5210 B-2011 (5) (h).
Requirement: Supporting Records shall be maintained as evidence that these practices
are implemented. Ref: 15A NCAC 02H .0805 (a) (7).
Comment: The laboratory does not have any logs for recording temperatures of the
BOD incubator and residue oven.
Recommendation: It is recommended that the laboratory use a temperature log for the
BOD incubator and residue oven.
E. Finding: The laboratory needs to increase the traceability documentation of purchased
materials and reagents, as well as documentation of standards and reagents prepared
in the laboratory.
Requirement: Chemical containers shall be dated when received and when opened.
Reagent containers shall be dated, identified, and initialed when prepared. Chemicals
and reagents exceeding the expiration date shall not be used. The laboratory shall have
a documented system of traceability for the purchase, preparation, and use of all
chemicals, reagents, standards, and consumables. Ref: 15A NCAC 2H .0805 (a) (7)
(K).
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 and 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 laboratory does not have a standard and reagent preparation log for the
preparation of dilution water and glucose/glutamic acid (GGA) for Biological Oxygen
Demand (BOD) and Suspended Residue check standards. An example standard and
reagent preparation log template was provided to the laboratory with instructions on use
at the time of the inspection.

#523 Mt. Olive Pickle Co. WWTP
Comment: Dates received and opened were written on the ammonia standard bottles,
chloride standard bottles, conductivity standard bottles and pH buffer bottles. While this
can provide a traceability link to analyses by looking at the dates that the chemicals
were in use, that link is lost once the bottles are discarded. An example receipt log
template was provided to the laboratory with instructions on use at the time of the
inspection.
F. Finding: Error corrections are not always properly performed.
Requirement: All documentation errors shall 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 shall 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 2H .0805 (a) (7) (E).
Comment: Error corrections on the October 5, 2019 BOD and May 2, 2019 TSS
benchsheets were not marked through once, dated and initialed.
G. Finding: The laboratory benchsheets for Ammonia, BOD, Chloride, Conductivity,
Dissolved Oxygen (DO), pH, TSS and Temperature are lacking required documentation:
the method or Standard Operating Procedure.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses and shall consist of: the method or
Standard Operating Procedure. Ref: 15 NCAC 2H .0805 (a) (7) (F) (i).
Comment: All these benchsheets lacked method descriptions.
H. Finding: The laboratory benchsheet for Ammonia, BOD, Conductivity, DO, pH, TSS and
Temperature are lacking required documentation: instrument identification.
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. Ref: 15 NCAC 2H .0805 (a) (7) (F) (iii).
I. Finding: The laboratory benchsheet for Ammonia, BOD, Conductivity, DO, pH, TSS and
Temperature are lacking required documentation: 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; the proper units of measure. Ref: 15 NCAC 2H .0805 (a) (7) (F) (xii).
J. Finding: The laboratory benchsheet for BOD is lacking required documentation: the
date and time of sample collection.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses and shall consist of: the date and
time of sample collection. Ref: 15 NCAC 2H .0805 (a) (7) (F) (vi).
K. Finding: The BOD benchsheet lacks documentation of DO meter calibration.

#523 Mt. Olive Pickle Co. VVWTP
Requirement: Supporting Records shall be maintained as evidence that these practices
are implemented. Ref: 15 NCAC 2H .0805 (a) (7).
L. Finding: The laboratory benchsheet for Chloride is lacking required documentation: the
date of sample analyses.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses and shall consist of: the date of
sample analyses. Ref: 15 NCAC 2H .0805 (a) (7) (F) (vii).
M. Finding: The thermometer in the BOD incubator is not verified against a Reference
Temperature -Measuring Device at least quarterly.
Requirement: Digital temperature -measuring devices and temperature -measuring
devices used in incubators shall be verified at the temperature of use every three months
against a Reference Temperature -Measuring Device and their accuracy shall be
corrected. Ref:15 NCAC 2H .0805 (a) (7) (N) (iii).
Comment: This laboratory was buying new traceable temperature measuring devices
annually for the BOD thermometer.
N. Finding: A second source standard is not analyzed for the Ammonia analyses.
Requirement: Laboratories shall analyze one known second source standard to verify
the accuracy of standard preparation if an initial calibration is performed and in
accordance with the referenced method requirements thereafter. Ref: 15A NCAC 2H
.0805 (a) (7) (H) (ii).
Requirement: When a standard curve is manually prepared (as opposed to a factory -set
calibration), it is required to analyze one known standard in addition to calibration
standards each day samples are analyzed to document accuracy. This standard must be
prepared from materials obtained from a source independent from the one used for
preparing the calibration standards (often referred to as a second source standard or
external reference standard). A second source standard may be:
• a quality control standard obtained from a vendor,
• a standard prepared from primary standards obtained from a second vendor, or
• a standard made from primary standards from the same vendor but from a different lot
number (i.e., an independent lot) as those used to make the calibration standards.
Laboratory control standards are evaluated to assess whether the lab is in control of the
processes involved in the preparation and analysis of specific tests. Laboratory control
standards must be similar in composition to the environmental samples. They must
contain known concentrations of all analytes of interest and undergo the same preparatory
and determinative procedures as the environmental samples.
Second source standards must be evaluated using one of the following: vendor supplied
criteria, method -defined acceptance criteria, in-house calculated acceptance limits that are
statistically -derived from historical data based on three standard deviations from the mean
in the detectable range or other statistically viable evaluation criterion. If the results fall
outside of acceptance limits, the analysis is out of control. The analysis must be

#523 Mt. Olive Pickle Co. WWTP
terminated and the problem corrected prior to sample analysis. Ref: NC WW/GW LC
Policy.
Comment: The laboratory is not analyzing a Laboratory Fortified Blank (LFB) made from
a second source standard.
®. Finding: A calibration blank and calibration verification standard are not being analyzed at
the end of each batch for the Ammonia analyses.
Requirement: A calibration blank and calibration verification standard shall be analyzed
prior to sample analysis, after every tenth sample, and at the end of each sample group,
unless otherwise specified by the method, to check for carryover and calibration drift.
Ref: 15A NCAC 2H .0805 (a) (7) (H).
P. Finding: The laboratory does not report results of all tests on the characteristics of the
effluent when duplicate sample analyses are performed.
Requirement: The results of all tests on the characteristics of the effluent, including but
not limited to NPDES permit monitoring requirements, shall be reported on the monthly
report forms. Ref: 15A NCAC 2B .0506 (b) (3) (J).
Comments: If more than one pH concentration has been measured on a particular day,
these values cannot be averaged due to the logarithmic nature of pH concentrations. All
values must be reported on the DMR, either in the daily cell or the comments section. The
following convention must be followed when deciding which value to report in the daily cell:
® Any value in violation of permit limits must be reported in the daily cell. If multiple
samples yielded noncompliant results, the most extreme noncompliant value must
be reported in the daily cell. The additional values must be reported in the DMR
comment section.
® If all values taken during the day were compliant with the permit limits, the value
closest to the bounds of the limit range (high or low) must be reported in the daily
cell. The additional values must be reported in the DMR comment section.
Comment: The laboratory is analyzing duplicates for Conductivity, DO, pH and
Temperature. Duplicates are not required for these parameters.
Nitrogen, Ammonia — Standard Methods, 4500 NH3 D-2011 (Aqueous)
Q. Finding: Samples are not warmed to approximately 25 °C prior to analysis.
Requirement: Maintain the same stirring rate and a temperature of about 25 °C
throughout calibration and testing procedures. Ref: Standard Methods, 4500 NH3 D-
2011. (4) (b).
Comment: The laboratory analyzes samples within 15 minutes of collection, however,
sometimes the temperature was not at 25 °C.
Recommendation: It is recommended that the laboratory acid preserve the samples to
pH <2 S.U. which would allow for extra time (more that 15 minutes) for samples to
equilibrate to 25 'C.

#523 Mt. Olive Pickle Co. WWTP
R. Finding: The laboratory is not using 100 mL of sample.
Requirement: Dilute if necessary to bring NH3-N concentration to within calibration
curve range. Place 100 mL sample in 150-mL beaker and follow procedure in ¶ b above.
Record volume of 10N NaOH added. Read NH3-N concentration from standard curve.
Ref: Standard Methods, 4500 NH3 B-2011 (4) (e).
Comment: The laboratory uses 25 mL of sample.
S. Finding: The laboratory is not analyzing an LFM/LFMD daily.
Requirement: When appropriate for the analyte (Table 4020:1), include at least one
LFM/LFMD daily or with each batch of 20 or fewer samples. Ref: Standard Methods, 4020-
2011 (2) (g).
Comment: The laboratory was analyzing a sample duplicate each day and only analyzing
an LFM monthly. However, an LFM/LFMD is required per Standard Methods, so a sample
duplicate may not be used in its place to demonstrate precision.
Recommendation: It is recommended that the laboratory use a volume of matrix spiking
solution that results in less than a 1 % dilution of the sample so that adjustments to the
matrix spike recovery calculation are not needed.
BOD — Standard Methods, B-2011 (Aqueous)
Comment: The BOD Incubator was used to store various laboratory standards, chemicals and
reagents.
Recommendation: It is recommended that the laboratory not use the BOD incubator for this
purpose.
T. Finding: Extra nutrient, mineral, and buffer solutions are not added to the BOD bottles
containing more than 67% (i.e., > 201 mL) sample. Cited previously on July 8, 2009.
Requirement: When a bottle contains more than 67% of the sample after dilution,
nutrients may be limited in the diluted sample and subsequently reduce biological
activity. In such samples, add the nutrient, mineral, and buffer solutions (3a through e)
directly to diluted sample at a rate of 1 mL/L (0.30 mL/300-mL bottle) or use
commercially -prepared solutions designed to dose the appropriate bottle size. Ref:
Standard Methods, 5210 B-2011. (5) (c) (2).
Comment: There have been many personnel changes since the previous inspection
where they were cited for this Finding.
U. Finding: Seed controls with less than 2.0 mg/L DO depletion are used for seed correction
calculation.
Requirement: For the ratio method, divide the DO depletion by the volume of seed in
milliliters for each seed control bottle having a 2.0 mg/L depletion and greater than 1.0
mg/L minimum residual DO and average the results. Ref: Standard Methods, 5210 13-
2011. (6) (d).
V. Finding: The BOD incubator temperature was not within the acceptable range.

#523 Mt. Olive Pickle Co. WWTP
Requirement: Sample incubation: Incubate at 20°C ± VC the stoppered and sealed
BOD bottles containing desired dilutions, seed controls (521013,6d), dilution water blanks
(5210B.6c), and glucose-glutamic acid checks (5210B.6b). Exclude light to avoid growth
of algae in the bottles during incubation. Ref: Standard Methods, 5210 B-2011 (5) (h).
Comment: The BOD incubator in the laboratory was at 240C during the inspection and,
despite attempts to lower the temperature, was reading 250C the next day.
W. Finding: Documentation does not demonstrate that the initial DO is measured within 30
minutes of sample preparation. This is considered pertinent data.
Requirement: After preparing dilution, measure initial DO within 30 min. Ref: Standard
Methods, 5210 B-2011. (5) (g).
Requirement: Supporting Records shall be maintained as evidence that these practices
are implemented. Ref: 15 NCAC 2H .0805 (a) (7).
X. Finding: The laboratory does not decant the supernatant after seed preparation.
Requirement: Decant the supernatant to another clean container (after preparation),
carefully leaving the bran behind. For the remainder of the test, gently stir and pipette
aliquots to BOD bottles from the supernatant. Ref: PolySeed® Manufacturer's
Instructions.
Chloride - Standard Methods, 4500-CI- B-2011 (Aqueous)
Y. Finding: The laboratory was using a buret with a broken tip.
Requirement: Facilities, Supplies, and Equipment. Each laboratory requesting
Certification shall be maintained so as to ensure the security and integrity of samples.
Samples shall be analyzed in such a manner that contamination or error will not be
introduced. Each facility shall contain or be equipped with the following:
(A) A source of water that will meet the minimum criteria of the approved
methodologies; and
(B) Glassware, chemicals, supplies, and equipment required to perform all tests,
analyses, measurements, or monitoring included in its Certification. Ref: 15 NCAC 2H
.0805 (a) (6) (B).
Z. Finding: The laboratory is not standardizing the AgNO, titrant.
Requirement: Directly titrate samples in the pH range 7 to 10. Adjust sample pH to 7 to
10 with HZSO, or NaOH if it is not in this range. For adjustment, preferably use a pH
meter with a non -chloride -type reference electrode. (If only a chloride -type electrode is
available, determine amount of acid or alkali needed for adjustment and discard this
sample portion. Treat a separate portion with required acid or alkali and continue analysis.)
Add 1.0 mL KZCrO, indicator solution. Titrate with standard AgNO3. titrant to a pinkish
yellow endpoint. Be consistent in endpoint recognition. Standardize AgNO, titrant and
establish reagent blank value by the titration method outlined above. Ref: Standard
Methods, 4500 Cl- B-2011. (4) (b).
AA. Finding: The laboratory is not analyzing an LFM/LFMD daily.

#523 Mt. Olive Pickle Co. WWTP
Requirement: When appropriate for the analyte (Table 4020:1), include at least one
LFM/LFMD daily or with each batch of 20 or fewer samples. Ref: Standard Methods, 4020-
2011 (2) (g).
Recommendation: It is recommended that the laboratory use a volume of matrix spiking
solution that results in less than a 1 % dilution of the sample so that adjustments to the
matrix spike recovery calculation are not needed.
Conductivity - Standard Methods, 2510 E-2011 (Aqueous)
DD. Finding: The Automatic Temperature Compensator (ATC) check is not being performed.
Requirement: The ATC must be verified prior to initial use and annually (i.e., 12
months) thereafter at two temperatures by analyzing a standard or sample at 25°C (i.e.,
the temperature to which conductivity values are reported) and a temperature(s) that
brackets the temperature ranges of the environmental samples routinely analyzed.
As the temperature increases or decreases, the value of the conductivity standard or
sample must be within ±10% of the true value of the standard or ±10% of the value of
the sample at 25°C. If not, corrective action must be taken. Ref: NC WW/GW LC
Approved Procedure for the Analysis of Specific Conductance (Conductivity).
CC. Finding: The laboratory is not analyzing a second -source calibration verification check
standard prior to analyzing compliance samples.
Requirement: Analyze and document a second -source calibration verification check
standard prior to compliance sample analysis. It is recommended that this standard
value approximate (may be higher or lower than the calibration standard, as applicable)
the expected range of sample values measured. Ref: NC WW/GW LC Approved
Procedure for the Analysis of Specific Conductance (Conductivity).
DD. Finding: The laboratory is not performing a post -analysis calibration verification when
analyzing multiple samples.
Requirement: When performing multiple sample analyses, a post -analysis calibration
verification must be analyzed at the end of the run. It is recommended that a mid -day or a
mid -batch calibration verification be performed when samples are analyzed over an
extended period of time. The value obtained for the post -analysis calibration verification
check -standard must read within 10% of the standard's true value. If the obtained value is
outside of the ±10% range, corrective action must be taken. If recalibration is necessary,
all samples analyzed since the last acceptable calibration verification must be reanalyzed,
if possible. If samples cannot be reanalyzed, the data must be qualified. Ref: NC
WW/GW LC Approved Procedure for the Analysis of Specific Conductance (Conductivity).
Dissolved Oxygen — Hach 10360-2011, Rev. 1.2 (LDO) (Aqueous)
EE. Finding: Documentation of the DO meter calibration does not include all variables.
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Calibration variables (temperature, elevation or barometric pressure
fin mmHgl, and salinity). Ref: NC WW/GW LC Approved Procedure for the Analysis of
Dissolved Oxygen (DO).

#523 Mt. Olive Pickle Co. WWTP
FF. Finding: The laboratory is not calibrating the meter at each sample site or performing a
post -analysis calibration verification when analyses are performed at multiple sample sites.
Requirement: When performing analyses at multiple sample sites, the meter must be
calibrated at each sample site prior to analysis or a post -analysis calibration verification
must be performed at the end of the run, regardless of meter type. The calculated
theoretical DO value must verify the meter reading within ±0.5 mg/L. If the meter
verification does not read within ±0.5 mg/L of the theoretical DO, corrective action must
be taken. If the meter is not calibrated at each sample site, it is recommended that a
mid -day calibration be performed when samples are extended over an extended period
of time. Ref: NC WW/GW LC Approved Procedure for the Analysis of Dissolved
Oxygen (DO).
pH — Standard Methods, 4500 H+D-2011 (Aqueous)
GG. Finding: The laboratory is not analyzing a check standard buffer after calibration and prior
to sample analysis.
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.
Ref: NC WW/GW LC Approved Procedure for the Analysis of pH.
HH. Finding: The laboratory is not performing a post -analysis calibration verification when
analyses are performed at multiple sample sites.
Requirement: When performing analyses at multiple sample sites, a post -analysis
calibration verification using the check standard buffer must be analyzed at the end of
the run. The post -analysis check standard buffer(s) must read within ±0.1 S.U. or
corrective actions must be taken. If recalibration is necessary, all samples analyzed
since the last acceptable calibration verification must be reanalyzed, if possible. If
samples cannot be reanalyzed, the data must be qualified. Ref: NC WW/GW LC
Approved Procedure for the Analysis of pH.
II. Finding: The pH 10 S.U. buffer is expired.
Requirement: Chemical containers shall be dated when received and when opened.
Reagent containers shall be dated, identified and initialed when prepared. Chemicals and
reagents exceeding the expiration date shall not be used. The laboratory shall have a
documented system of traceability for the purchase, preparation and use of all chemicals,
reagents, standards and consumables. Ref: 15 NCAC 2H .0805 (a) (7) (K).
Residue, Suspended — Standard Methods, 2540 D-2011 (Aqueous)
Comment: Suspended Residue is considered a method -defined parameter per the definition in
the Code of Federal Regulations, Part 136.6, Section (a) (5). This means that per Section (b) (3),
the method may not be modified.
Comment: Effective January 1, 2021, NC WW/GW LC will no longer allow drying studies or dry
filter blanks to substitute for drying and weighing to a constant weight. Prior to filtering samples,
all filters will have to be washed and dried to a constant weight (within 0.5 mg of the prior weight).

#523 Mt. Olive Pickle Co. WWTP
All filters after filtering samples will also have to be dried and weighed to a constant weight (within
0.5 mg of the prior weight).
Comment: The laboratory is analyzing a water blank, which is not required by the method.
Comment: The laboratory was using a total immersion thermometer in the residue oven which
was seated improperly and read 105 °C. The EPA User -Friendly Guidance on the Replacement of
Mercury Thermometers states: Thermometers with no indicated depth are the total immersion
type. When a partial -immersion thermometer is used, the bottom of the thermometer up to the
immersion line should be exposed to the temperature being measured, with the remainder of the
thermometer exposed to ambient conditions. When a total immersion thermometer is used, the
bulb and the entire portion of the stem containing liquid, except for the last 1 cm, are exposed to
the temperature being measured. If the thermometer is not used in this manner, the thermometer
immersion is incorrect. Acceptable corrective action (i.e. the total immersion thermometer was
inserted the proper amount into the residue oven) was performed by the laboratory and approved
by the auditor during the inspection. After corrective action the temperature on the thermometer
initially read 115 'C. Temperature adjustments were made to the residue oven and it
subsequently fell to 105 °C. No further response is necessary for this Corrected Finding.
JJ. Finding: A check standard is not being analyzed quarterly.
Requirement: Analyze one suspended residue, one dissolved residue, one residual
chlorine and one oil and grease standard quarterly. Ref: 15 NCAC 2H .0805 (a) (7) (B).
Comment: The revised Rule [15 NCAC 2H. 0805 (a) (7) (G)] requires the laboratory to
analyze one standard monthly during each month samples are analyzed. This must be
implemented by December 31, 2019.
KK. Finding: The samples are not dried at 103 to 105'C.
Requirement: A well -mixed sample is filtered through a weighed standard glass -fiber filter
and the residue retained on the filter is dried to a constant weight at 103 to 105°C. The
increase in weight of the filter represents the total suspended solids. If the suspended
material clogs the filter and prolongs filtration, it may be necessary to increase the
diameter of the filter or decrease the sample volume. To obtain an estimate of total
suspended solids, calculate the difference between total dissolved solids and total solids.
Ref: Standard Methods, 2540 D-2011 (1) (a).
Comment: The laboratory was mistakenly using 103 to 107 °C as the temperature range
requirement of the residue oven. Also, the laboratory had incorrectly inserted the
thermometer in the residue oven. When the thermometer was inserted at the proper
position in the oven it read 115°C.
ILL. Finding: The laboratory is not analyzing a volume of sample to yield a minimum of 2.5
mg dried residue.
Requirement: Choose sample volume to yield between 2.5 and 200 mg dried residue.
If volume filtered fails to meet minimum yield, increase sample volume up to 1 L. If
complete filtration takes more than 10 min, increase filter diameter or decrease sample
volume. Ref: Standard Methods, 2540 D-2011 (3) (b).

#523 Mt. Olive Pickle Co. WWTP
Comment: The laboratory only filtered 500 mL of effluent and, at times, didn't meet the
2.5 mg minimum weight.
MM. Finding: The laboratory is not basing the reporting limit on the minimum weight gain
required by the method.
Requirement: The minimum weight gain allowed by any approved method is 2.5 mg.
Choose sample volume to yield between 2.5 and 200 mg dried residue. This establishes
a minimum reporting value of 2.5 mg/L when 1000 mL of sample is analyzed. If
complete filtration takes more than 10 minutes increase filter diameter or decrease
sample volume. In instances where the weight gain is less than the required 2.5 mg, the
value must be reported as less than the appropriate value based upon the volume used.
Ref: NC WW/GW LC Policy.
Comment: On August 1, 2019 the laboratory reported a result of 2 mg/L on their DMR
when they should have reported <5 mg/L based on their 500 mL filtering volume.
NN. Finding: Filters are not weighed to constant weight prior to sample analysis, nor is a dry
filter blank analyzed with each set of samples.
Requirement: If pre -prepared filters are not used, the method requires that filters must
be weighed to a constant weight after washing. Repeat cycle of drying, cooling,
desiccating, and weighing until a constant weight is obtained or until weight change is
less than 4% of the previous weighing or 0.5 mg, whichever is less. In lieu of this
process, it is acceptable to analyze a single daily dry filter blank to fulfill the method
requirement of drying all filters to a constant weight prior to analysis. This is performed
by washing all filters as required by the method, then drying and desiccating them. The
process of repeatedly heating, cooling, desiccating, and weighing until a constant weight
is documented is not required. Instead, a single dry blank filter (i.e., no additional rinsing
during the analysis) is analyzed. The acceptance criterion for the blank is a weight
change of less than 4% of the filter's initial weight or 0.5 mg, whichever is less. Ref: NC
WW/GW LC Policy.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North
Carolina Division of Water Resources. Data were reviewed for Mt. Olive Pickle Co. WWTP
(NPDES permit # NC0001074) for January, April and August 2019. The following errors were
noted:
Date
Parameter
Location
Value on Benchsheet
Value on DMR
4/10/2019
Suspended Residue
Effluent
7.12 mg/L
7.2 mg/L
8/9/2019
Temperature
Effluent
30 °C
31 °C
V. CONCLUSIONS:

#523 Mt. Olive Pickle Co. WWTP
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 action.
Report prepared by: Tom Halvosa
2019
Report reviewed by: Jason Smith
2019
Date: November 26,
Date: November 27,

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