#5488_2017_0525_JS_FINAL

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5488
Laboratory Name:
Cliffside Sanitary District
Inspection Type:
Field Municipal Maintenance
Inspector Name(s):
Jason Smith
Inspection Date:
May 25, 2017
Date Forwarded for Initial
Review:
June 16, 2017
Initial Review by:
Tonja Springer
Date Initial Review
Completed:
June 16, 2017
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:
June 19, 2017
Date Forwarded to Admin.:
June 20, 2017
Date Mailed:
June 20, 2017
Special Mailing Instructions:

Water Resources
ENVIRONMENTAL .QUALITY
June 20, 2017
5488
Mr. Mike Gibert
Cliffside Sanitary District
P. O. Box 122
Cliffside, NC 28024
ROY COOPER
MICHEAL S. REGAN
S. JAY ZIMMERMAN
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Gibert:
Enclosed is a report for the inspection performed on May 24, 2017 by Jason Smith. 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,
D �a
Todd Crawford
Technical Assistance & Compliance Specialist
NC WW/GW Laboratory Certification Branch
Attachment
cc: Dana Satterwhite, Jason Smith, Master File 5488

LABORATORY NAME:
NPDES PERMIT#:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
r• • • • ,117
Cliffside Sanitary District
NC0004405
136 Hawkins Loop Rd
Mooresboro, NC 28114
5488
May 25, 2017
Field Municipal Maintenance
Jason Smith
LOCAL PERSON(S) CONTACTED: Mike Gibert
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 2H .0800 for the analysis of environmental samples.
II. GENERAL COMMENTS:
The facility has all the equipment necessary to perform the analyses. The laboratory analyst was
very forthcoming and receptive to implementing the necessary changes in response to the
Findings and Recommendations made during the inspection.
All required Proficiency Testing (PT) samples for the 2017 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, 2017.
Contracted analyses are performed by Pace Analytical Services, LLC — Huntersville, NC
(Certification #12).
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.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
Recommendation: It is recommended that the method references on the benchsheets be
updated to match the laboratory's Certified Parameter List (CPL). The benchsheets currently
reference 18th Edition of Standard Methods.
A. Finding: The laboratory needs to increase the traceability documentation of purchased
reagents.

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#5488 Cliffside Sanitary District
Requirement: All consumables used by the laboratory must have the following
information documented: Date Received, Date Opened (in use), Vendor, Lot Number,
and Expiration Date. 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. Ref: Quality Assurance Policies for Field Laboratories.
Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A
NCAC 2H .0805 (g) (1).
Comment: Date received and opened were written on the reagent containers for Total
Residual Chlorine and pH. 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.
B. Finding: Data that does not meet all quality control (QC) requirements is not qualified on
the electronic Discharge Monitoring Report (eDMR).
Requirement: When QC failures occur, the laboratory must attempt to determine the
source of the problem and must apply corrective action. Part of the corrective action is
notification to the end user. If data qualifiers are used to qualify samples not meeting QC
requirements, the data may not be useable for the intended purposes. It is the
responsibility of the laboratory to provide the client or end -user of the data with sufficient
information to determine the usability of the qualified data. Where applicable, a notation
must be made on the electronic Discharge Monitoring Report (eDMR) form, when any
required sample quality control does not meet specified criteria and another sample
cannot be obtained. Ref: Quality Assurance Policies for Field Laboratories.
Comment: The laboratory qualified data prior to using the eDMR in July 2016. This
practice was discontinued because the permittee was unaware of how to report them in
the eDMR system. Technical assistance was provided at the time of the inspection and the
laboratory should contact the Asheville Regional Office if any more difficulties are
encountered.
Quality Control
C. Finding: Reagents are used beyond the expiration date.
Requirement: Adherence to manufacturer expiration dates is required. Chemicals,
reagents, standards, consumables exceeding the expiration date can no longer be
considered reliable. If the expiration is only listed as a month and year (with no specific day
of the month), the last day of the month will be considered the actual date of expiration.
Monitor materials for changes in appearance or consistency. Any changes may indicate
potential contamination and the item should be discarded even if the expiration date is not
exceeded. If no expiration date is given, the laboratory must have a policy for assigning an
expiration date. If no date received or expiration date can be determined, the item should
be discarded. Ref: Quality Assurance Policies for Field Laboratories.
Comment: The Total Residual Chlorine (TRC) buffer and DPD liquid reagents expired in
February 2017.
Proficiency Testing
D. Finding: The preparation of Proficiency Testing (PT) samples is not documented.

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#5488 Cliffside Sanitary District
Requirement: PT samples received as ampules must be diluted according to the PT
provider's instructions. The preparation of PT samples must be documented in a
traceable log or other traceable format. The diluted PT sample becomes a routine
environmental sample and is added to a routine sample batch for analysis. Ref:
Proficiency Testing Requirements, February 20, 2012, Revision 1.2.
Comment: Dating and initialing the instruction sheet for the preparation of the TRC PT
would satisfy the documentation requirement.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) and contract lab reports to eDMRs submitted to the North Carolina Division of Water
Resources. Data were reviewed for the Cliffside Sanitary District (NPDES permit #NC0004405)
for July, September and December 2016. No transcription errors were detected. The facility
appears to be doing a good job of accurately transcribing data.
V. CONCLUSIONS:
Correcting the above -cited Findings and implementing the Recommendation 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 and implementation
dates for each corrective action.
Report prepared by: Jason Smith Date: June 16, 2017
Report reviewed by: Tonja Springer Date: June 16, 2017

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