#5342_2017_0623_BS_FINAL

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5342
Laboratory Name:
Pace Analytical Services LLC — Field Services NC
Inspection Type:
Field Commercial Maintenance
Inspector Name(s):
Beth Swanson, Gary Francies and Jason Smith
Inspection Date:
May 16, June 1 and June 23, 2017
Date Forwarded for Initial
June 29, 2017
Review:
Initial Review by:
Jason Smith
Date Initial Review
July 5, 2017
Completed:
❑ Insp. Initial ® Insp. Reg
Cover Letter to use:
❑Insp. No Finding ❑Insp. CP
❑Corrected
❑Insp. Reg. Delay
Unit Supervisor/Chemist III:
Gary Francies
Date Received:
7/5/17
Date Forwarded to Admin.:
7/14/17
Date Mailed:
qT' 7
Special Mailing Instructions:
Wes Bell, MRO

Water Resources
rNVtFYONMENTAL QUA Li TY
July 14, 2017
5342
Ms. Cheryl Johnson
Pace Analytical Services LLC - Field Services NC
9800 Kincey Avenue - Suite 100
Huntersville, NC 28078-
ROY COOPER
MICHEAL S. REGAN
S. JAY ZIMMERMAN
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Ms. Johnson:
Enclosed is a report for the inspection performed on May 16, June 1, and June 23, 2017 by Beth
Swanson, Jason Smith, and myself. 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. Ifyouwish 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,
Gary Francies, Technical Assistance/Compliance Specialist
Division of Water Resources
Attachment
cc: Beth Swanson
master file

LABORATORY NAME:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
I. INTRODUCTION:
Pace Analytical Services, LLC — Field Services NC
9800 Kincey Avenue - Suite100
Huntersville, NC 28078
5342
May 16, 2017, June 1, 2017 and June 23, 2017
Field Commercial Maintenance
Beth Swanson, Gary Francies and Jason Smith
Cheryl Johnson, Mark Swann (Asheville), Colley Frank
(Huntersville) and William Thomas (Raleigh)
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:
The laboratory currently has staff performing field analyses out of four locations: Eden, Asheville,
Huntersville and Raleigh. An abbreviated audit of the Eden -based analysts was performed August
25, 2015 and the report was sent September 11, 2015. Previous to that time, separate audits
were conducted in July through September 2010 to inspect the three locations in operation at that
time and were presented in one report. This report will combine Findings from the inspections of
the Raleigh, Huntersville and Asheville -based field operations.
All required Proficiency Testing (PT) samples have been analyzed for the 2017 PT calendar year
and the graded results were 100% acceptable.
Current 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.
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.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Proficiency Testing
A. Finding: PT Samples are not equally distributed among qualified personnel from year to
year.

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#5342 Pace Analytical Services, LLC — Field Services NC
Requirement: Laboratories shall also ensure that, from year to year, PT Samples are
equally distributed among personnel trained and qualified for the relevant tests and
instrumentation (when more than one instrument is used for routine Compliance Sample
analyses), that represents the routine operation of the work group at the time the PT
Sample analysis is conducted. Ref: Proficiency Testing Requirements, May 31, 2017,
Revision 2.0.
Documentation
Recommendation (Huntersville, Raleigh): It is recommended that the field analysts document
any equipment maintenance in their field notebooks, such as when membranes or probes are
changed.
Recommendation (Huntersville): It is recommended that the column header "open date" found
in some field notebooks be changed to "in use". The true open date is recorded in the reagent
receipt log and the dates documented in field notebooks are when the individual analyst begins
using it.
Comment (Asheville): Vendor information was missing from the traceability documentation. The
analysts employ field notebooks where traceability information is maintained. The NC WW/GW
LC Quality Assurance Polices for Field Laboratories document states: 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.
This information as well as the vendor and/or manufacturer, lot number, and expiration date must
be retained for chemicals, reagents, standards and consumables used for a period of five years.
Consumable materials such as pH buffers and lots of pre -made standards are included in this
requirement. Acceptable corrective action (i.e., the analysts added a space to document vendor
information for reagents and added the information for the current items in their field notebook)
was performed by the laboratory and approved by the auditor during the inspection. No further
response is necessary for this Finding.
Comment (Asheville): Only one time was documented on the field logs without noting that
samples were analyzed immediately on site. This does not clearly demonstrate that samples are
analyzed within holding time. The NC WW/GW LC Approved Procedure for the Analysis of
Specific Conductance (Conductivity), NC WW/GW LC Approved Procedure for the Analysis of
Dissolved Oxygen, NC WW/GW LC Approved Procedure for the Analysis of Total Residual
Chlorine, and NC WW/GW LC Approved Procedure for the Analysis of pH documents state: The
following must be documented in indelible ink whenever sample analysis is performed: Date and
time of sample collection. Date and time of sample analysis to verify the holding time is met.
Alternatively, one time may be documented for collection and analysis with the notation that
samples are measured in situ or immediately at the sample site. The NC WW/GW LC Approved
Procedure for the Analysis of Temperature document states: The following must be documented
in indelible ink whenever sample analysis is performed: Date and time of sample collection. Date
and time of sample analysis - Alternatively, since EPA requires samples to be analyzed
immediately, one time may be documented for collection and analysis with the notation that
samples are measured in situ or immediately at the sampling site (i.e., immediately following
collection at a location as near to the collection point as possible). When this `one time' option is
used, state that the documented time is both collection and analysis time. Acceptable corrective
action (i.e., the analysts added a statement at the beginning of their field notebook that unless
otherwise noted, the time documented is both collection and analysis time) was performed by the
laboratory and approved by the auditor during the inspection. No further response is necessary
for this Finding.

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#5342 Pace Analytical Services, LLC — Field Services NC
B. Finding (Asheville, Huntersville): Error corrections are not always properly performed.
Requirement: All documentation errors must 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. Write the correction adjacent to the error. The correction must be
initialed by the responsible individual and the date of change documented. Ref: Quality
Assurance Policies for Field Laboratories.
C. Finding (Huntersville): The laboratory does not document the date received of
purchased materials and reagents in the receipt log.
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). 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: Quality Assurance
Policies for Field Laboratories.
Chlorine, Total Residual — Standard Methods, 4500 Cl G-2000 (Aqueous)
Recommendation (Asheville, Raleigh): The low -range curve is verified with standard
concentrations of 10 (in Raleigh), 15 (in Asheville), 50, 100, 200 and 400 pg/L. It is recommended
that a standard be verified between the lowest standard concentration and 50 pg/L in place of the
100 pg/L standard to put emphasis on the compliance level portion of the curve.
D. Finding (Raleigh): The laboratory is not documenting the assigned true value of the daily
check standard for the Hach Pocket 11 colorimeter.
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: True value of the check standard. Ref: NC WW/GW LC Approved
Procedure for the Analysis of Total Residual Chlorine.
Comment: The check standard has been assigned a value, however, the analyst was
documenting a range that had been written on the standard by another individual as the
true value. The check standards reviewed were acceptable based on the actual true value
assigned.
E. Finding (Asheville, Huntersville): The laboratory is not analyzing a reagent blank with
prepared standards.
Requirement: Reagent Blank: A reagent blank (sometimes also referred to as a method
blank) is only required when laboratory water is used to make quality control and/or
calibration standards. If you are using a sealed standard (e.g., gel) for your daily check
standard, a reagent blank would only be analyzed when preparing the annual 5-point
calibration curve or 5 annual calibration curve verification standards. Ref: NC WW/GW LC
Approved Procedure for the Analysis of Total Residual Chlorine.
Comment: The laboratory currently only prepares standards for the curve verification.
F. Finding (Raleigh): The laboratory is not documenting the analysis of the reagent blank
when the curve verification standards are prepared. This is considered pertinent data.

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#5342 Pace Analytical Services, LLC — Field Services NC
Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A
NCAC 2H .0805 (g) (1).
Requirement: Reagent Blank: A reagent blank (sometimes also referred to as a method
blank) is only required when laboratory water is used to make quality control and/or
calibration standards. If you are using a sealed standard (e.g., gel) for your daily check
standard, a reagent blank would only be analyzed when preparing the annual 5-point
calibration curve or 5 annual calibration curve verification standards. Ref: NC WW/GW LC
Approved Procedure for the Analysis of Total Residual Chlorine.
Conductivity — EPA 120.1, Rev. 1982 (Aqueous)
Conductivity —Standard Methods, 2510 B-1997 (Aqueous)
G. Finding (Huntersville, Raleigh): The Automatic Temperature Compensator (ATC) has
not been verified at 25°C.
Requirement: The Automatic Temperature Compensator (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. Ref: NC WW/GW LC Approved Procedure for the Analysis of
Specific Conductance (Conductivity).
Comment: The laboratory currently verifies the ATC at approximately room temperature
(e.g., 19-22°C) instead of 25 ± 0.5°C.
H. Finding (Raleigh): The ATC verification at 350C is not within ±10% of the true value of the
standard.
Requirement: 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).
Comment: The ATC was verified on February 6, 2017 and the 1000 pS/cm standard
heated to 35°C read 1712 pS/cm, which is not acceptable.
Dissolved Oxygen — Standard Methods, 4500 O G-2001 (Aqueous)
Finding (Huntersville, Raleigh): The true value of the post analysis calibration
verification is not documented.
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed. True value and value obtained for the post analysis calibration
verification(s), where applicable. Ref: NC WW/GW LC Approved Procedure for the
Analysis of Dissolved Oxygen (DO).
J. Finding (Huntersville): The post analysis calibration verification acceptance criterion is
±10% of true value.
Requirement: The calculated DO value must verify the meter reading within ±0.5 mg/L.
Ref: NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen.

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#5342 Pace Analytical Services, LLC — Field Services NC
K. Finding (Raleigh): The acceptability of the post analysis calibration verification is not
evaluated.
Requirement: The calculated DO value must verify the meter reading within ±0.5 mg/L.
Ref: NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen.
Comment: The analyst records the DO value, temperature and barometric pressure at
the end of the day in 100% moisture but does not evaluate whether that value is
acceptable. Since the information recorded can be used to determine the theoretical
values after the fact, a few verifications were evaluated during the inspection and were
within acceptable limits.
Dissolved Oxygen — Standard Methods, 4500 O G-2001 (Aqueous)
pH — Standard Methods, 4500 H+ B-2000 (Aqueous)
L. Finding (Huntersville): No corrective action is applied when post analysis calibration
verifications do not meet acceptance criteria.
Requirement: If the meter verification does not read within ±0.5 mg/L of the theoretical
DO, corrective action must be taken. Ref: NC WW/GW LC Approved Procedure for the
Analysis of Dissolved Oxygen.
Requirement: The post analysis check standard buffer(s) must read within ±0.1 S.0 or
corrective actions must be taken. Ref: NC WW/GW LC Approved Procedure for the
Analysis of pH.
Comment: Several instances were observed where the laboratory's acceptance criterion
for the post analysis DO and pH checks were exceeded and no corrective action was
taken (e.g., flag the data, recalibrate and reanalyze, etc). For DO, this was noted in the
field notebook "Greg Grogan Book #4" in March and May 2017.
Comment: It appears there are some issues when the check buffer is analyzed at
extreme low temperatures (e.g., 1.6°C on March 15, 2017 in Jameson Humonvey Book
#1). The true value of the buffer changes at different temperatures and the analysts are
not always documenting and comparing it to the true value at the corresponding
temperature.
IV. PAPER TRAIL INVESTIGATION:
Asheville
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water
Resources. Data were reviewed for Ohio Electric (NPDES permit # NC0039152) for January
and February 2017. The inspector mentioned during data review that less than ("<") symbols
can be recorded on the DMR for results that are below the reporting limit, which would then be
treated as zero for averaging purposes. No transcription errors were detected. The facility
appears to be doing a good job of accurately transcribing data.
Huntersville
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) and client reports. Data were reviewed for the following project numbers: #92340797
(Firestone, May 15, 2017) and #J17040246 (Duke Marshall, May 4, 2017). No transcription errors
were detected. The facility appears to be doing a good job of accurately transcribing data.

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#5342 Pace Analytical Services, LLC — Field Services NC
Raleigh
No paper trail performed.
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 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.
Report prepared by: Beth Swanson Date: June 29, 2017
Report reviewed by: Jason Smith Date: July 5, 2017