#5373_2018_0320_TH_FINAL

To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5373
Laboratory Name:
Town of Cary
Inspection Type:
Field Municipal Maintenance
Inspector Name(s):
Tom Halvosa, Todd Crawford
Inspection Date:
March 20, 2018
Date Forwarded for Initial
Review:
April 5, 2018
Initial Review by:
Jason Smith
Date Initial Review
Completed:
April 12, 2018
Cover Letter to use:
❑ Insp. Initial ® Insp. Reg
❑Insp. No Finding ❑Insp. CP
❑Corrected
❑Insp. Reg. Delay
Unit Supervisor/Chemist III:
Todd Crawford
Date Received:
April 12, 2018
Date Forwarded to Admin.:
April 17, 2018
Date Mailed:
April 17, 2018
Special Mailing Instructions:

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April 17, 2018
5373
Mr. Rick Jordan
Town of Cary
400 James Jackson Ave.
Cary, NC 27513
ROY COOPER
MICHEAL S. REGAN
LINDA CULPEPPER
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Jordan:
Enclosed is a report for the inspection performed on March 20, 2018 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 Fihding(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].
Sincerely,
D�
Todd Crawford
Technical Assistance & Compliance Specialist
NC WW/GW Laboratory Certification Branch
Attachment
cc: Dana Satterwhite, Tom Halvosa

WATER QUALITY PERMIT #:
CERTIFICATE :
TYPE OF INSPECTION:
AUDITORS:
LOCAL PERSONS CONTACTED:
INTRODUCTION:
Town of Cary
NC0048879 and NC0065102
WQ0018489 and WQ0017923
400 James Jackson Avenue
Cary, NC 27513
5373
March 20, 2018
Field Municipal Maintenance
Tom Halvosa and Todd Crawford
Rick Jordan and Kenya D'Jon
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.
GENERAL COMMENTS:
The facility has all the equipment necessary to perform the analyses. Staff were forthcoming and
seemed eager to adopt necessary changes. The laboratory separates their benchsheets into a
"calibration" benchsheet and a "point of use" benchsheet for recording calibration and compliance
data respectively.
All required Proficiency Testing (PT) Samples for the 2018 PT Calendar Year have not yet been
analyzed. The laboratory is reminded that results must be received by this office directly from the
vendor by September 30, 2018.
Requirements that reference 15A NCAC 2H .0805 (g) (1), stating "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", are
intended to be a requirement to document all pertinent information for historical reconstruction of
data. It is not intended to imply that existing records are not adequately maintained unless the
Finding speaks directly to that.

Page 2
#5373 Town of Cary
Required analyses beyond the capability of this laboratory are performed by North Cary WRF
(Certification # 107) and South Cary WRF (Certification # 278).
Quality Assurance Policies for Field Laboratories and Approved Procedure documents for the
analysis of the facility's currently certified Field Parameters were provided at the time of the
inspection.
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Documentation
Comment: During the inspection, the recommendation was made to document the acceptance
range of the Daily Check Standard to make confirmation of the acceptability easier. The
recommendation was accepted and the benchsheets were updated to include acceptance
criterion of ± 10% recovery for the Daily Check Standard and immediately put into use.
A. Finding: The laboratory benchsheet was lacking pertinent data: true value for the check
standard, facility name, instrument identification (serial number preferred), parameter
analyzed and method reference.
Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A
NCAC 2H .0805 (g) (1).
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Facility name, parameter analyzed, method reference and
thermometer/instrument identification (serial number preferred). Ref: NC WW/GW LC
Approved Procedure for the Analysis of Total Residual Chlorine, NC WW/GW LC
Approved Procedure for the Analysis of pH and NC WW/GW LC Approved Procedure for
the Analysis of Temperature.
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: True value of the Daily Check Standard(s). Ref: NC WW/GW LC
Approved Procedure for the Analysis of Total Residual Chlorine.
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: True value for the check standard buffer. Ref: NC WW/GW LC
Approved Procedure for the Analysis of pH.
Comment: For the analysis of Total Residual Chlorine, the true value of the gel -type
standard used for the Daily Check Standard was incorrectly listed on the calibration
benchsheet as 1.59 mg/L. The actual true value established at the time of the annual
Factory -set Calibration Curve Verification procedure was 1.5 mg/L.
B. Finding: The laboratory needs to increase the traceability 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. Consumable materials such as pH
buffers and lots of pre -made standards are included in this requirement. Ref: Quality
Assurance Policies for Field Laboratories.

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#5373 Town of Cary
Comment: The laboratory does not document the vendor name for pH buffers in
traceability documents.
Proficiency Testing
C. Finding: The laboratory is not documenting the preparation of PT Samples.
Requirement: PT Samples received as ampules are diluted according to the
Accredited PT Sample Provider's instructions. It is important to remember to document
the preparation of PT Samples in a traceable log or other traceable format. The diluted
PT Sample then becomes a routine Compliance Sample and is added to a routine
sample batch for analysis. No documentation is needed for whole volume PT Samples
which require no preparation (e.g., pH), but it is recommended that the instructions be
maintained. Ref: Proficiency Testing Requirements, May 31, 2017, Revision 2.0.
Comment: Dating and initialing the instruction sheet for each prepared TRC PT Sample
would satisfy the documentation requirement.
D. Finding: The laboratory is not documenting PT Sample analyses in the same manner as
routine Compliance Samples.
Requirement: All PT Sample analyses must be recorded in the daily analysis records as
for any Compliance Sample. This serves as the permanent laboratory record. Ref:
Proficiency Testing Requirements, May 31, 2017, Revision 2.0.
Temperature — Standard Methods, 2550 B-2010 (Aqueous)
E. Finding: The laboratory is not performing the annual temperature -measuring device
check procedure correctly.
Requirement: To check a compliance temperature -measuring device, compare readings
at two temperatures that bracket the range of compliance samples routinely analyzed
against a National Institute of Standards and Technology (NIST) traceable temperature -
measuring device and record all four readings. The readings from both devices must
agree within 0.5°C. Ref: NC WW/GW LC Approved Procedure for the Analysis of
Temperature.
Comment: The laboratory only checks the temperature -measuring device at one
temperature.
IV. PAPER TRAIL INVESTIGATION:
This facility does not report compliance data on an electronic Discharge Monitoring Report
(eDMR). Their compliance data is recorded and retained as part of a permit requirement of
another parent facility (North Cary WRF). As such, a paper trail could not be performed.
V. CONCLUSIONS:
Correcting the above -cited Findings will help this laboratory 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 and include supporting
documentation and implementation dates for each corrective action.

Page 4
#5373 Town of Cary
Report prepared by: Tom Halvosa Date: April 5, 2018
Report reviewed by: Jason Smith Date: April 12, 2018

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