#5387_2016_1117_BS_FINAL

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
Laboratory Name:
Inspection Type:
Inspector Name(s):
Inspection Date:
Date Report Completed:
Date Forwarded to Reviewer:
Reviewed by:
Date Review Completed:
Cover Letter to use:
Unit Supervisor/Chemist III:
Date Received:
Date Forwarded to Admin:
Date Mailed:
5387
City of Kannapolis
Field Maintenance
Beth Swanson
November 17, 2016
December 5, 2016
December 5, 2016
Anna Ostendorff
December 8, 2016
❑ Insp. Initial ❑ Insp. Reg.
❑ Insp. No Finding ❑ Insp. CP
® Corrected ❑ Insp. Reg. Delay
Gary Francies
December 8, 2016
12/09/2016
12/09/2016
Special Mailing Instructions: mail to Wes Bell (a)- wes.bell(a�ncdenr.gov

W o P er' R esou rce.s
E N Vf rPONM EN IAL QUALI1 Y
December 9, 2016
5387
Mr. Gerald Faulkner
City of Kannapolis
401 Laureate Way
Kannapolis, NC 28081
PAT MCCRORY
DONALD R. VAN DER VAART
S. JAY ZIMMERMAN
SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Faulkner:
Enclosed is a report for the inspection performed on November 17, 2016 by Beth Swanson. Since the
Finding(s) cited during the inspection were all corrected prior to the completion of the enclosed report, a
response is not required. The staff is commended for taking the initiative in correcting the Findings in
such a timely manner. For Certification maintenance, your laboratory must continue to carry out the
requirements set forth in 15A NCAC 2H .0800.
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,
Gary Francies, Technical Assistance/Compliance Specialist
Division of Water Resources
Attachment
Cc: master file
Beth Swanson
Water Sciences Section
NC Wastewater/Groundwater Laboratory Certification Branch
1623 Mall Service Center, Raleigh, North Carolina 27699-1623
Location: 4405 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone]
Internet: http:1/deq.nc.govfabouUdivision s/water-resourcestwater-resources-dataiwater-sciences-home-page/laboratory-certification- bran ch

LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
On -Site Inspection Report
City of Kannapolis
NC0006220
1353 Pump Station Rd
Kannapolis, NC 28081
5387
November 17, 2016
Field Municipal Maintenance
Beth Swanson
LOCAL PERSON(S) CONTACTED:
I. INTRODUCTION:
Gerald Faulkner
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 laboratory is spacious and clean. The analyst was forthcoming and receptive to
recommendations and necessary changes.
All required Proficiency Testing (PT) samples have been analyzed for the 2016 PT calendar year
and the graded results were 100% acceptable.
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.
Contracted analyses are performed by Environment 1, Inc. (Certification #10).
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
Comment: The laboratory needed to increase traceability for consumables and some reagents.
The reagents used to make the Total Residual Chlorine (TRC) standards were traceable and their
preparation was documented. However, there was no traceability information retained for DPD

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#5387 City of Kannapolis
powder or pH buffers. The Quality Assurance Policies 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. Notification of acceptable corrective action (i.e., a copy of the
reagent receipt log implemented December 2, 2016 with columns to enter all required traceability
information) was received by email on December 2, 2016. No further response is necessary for
this Finding.
Proficiency Testing
Comment: A new analyst is currently in training. It was discussed at the inspection that once this
analyst is fully trained they will need to be included in a rotation for analyzing the annual PT
samples.
Comment: The preparation of the TRC PT sample was not being documented. The Proficiency
Testing Requirements, February 20, 2012, Revision 1.2 document states: 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.
Notification of acceptable corrective action (i.e., statements that beginning with the 2017 PT study,
the TRC instruction sheet from the PT vendor will be signed and dated by the analyst to document
they have followed the preparation directions) was received by email on December 2, 2016. No
further response is necessary for this Finding.
Comment: The laboratory was not documenting PT sample analyses in the same manner as
environmental samples. The Proficiency Testing Requirements, February 20, 2012, Revision 1.2
document states: All PT sample analyses must be recorded in the daily analysis records as for
any environmental sample. This serves as the permanent laboratory record. Notification of
acceptable corrective action (i.e., a statement that beginning with the 2017 PT study, the PT
results will be entered onto the laboratory's sample analysis log like a routine environmental
sample) was received by email on December 2, 2016. No further response is necessary for
this Finding.
Chlorine, Total Residual — Standard Methods, 4500 Cl G-2000 (Aqueous)
Recommendation: The laboratory currently verifies the calibration curve with standards at 25,
100, 200, 300 and 400 pg/L. It is recommended that the following standards be used: 25, 50, 200,
400 and one concentration between 25 pg/L and the 50 pg/L compliance limit.
Comment: The calibration verifications reviewed were within the proper limits, but the analyst was
unaware of the requirement that standards <50 pg/L must recover within ±25% and standards >_50
pg/L must recover within ±10%. The analyst stated that the laboratory will use the TRC calibration
verification spreadsheet provided by NC WW/GW LC starting in 2017, which automatically
includes this evaluation.
Comment: The laboratory was not analyzing a reagent blank with the annual standard curve
verification. The NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine
document states: Each day that prepared standards are analyzed, a reagent blank must be
analyzed. A reagent blank is made from the same laboratory water source used to make quality
control and/or calibration standards with DPD. The concentration of reagent blanks must not

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exceed 50% of the reporting limit (i.e., the lowest calibration or calibration verification standard
concentration), unless otherwise specified by the reference method, or corrective action must be
taken. Notification of acceptable corrective action (i.e., a statement that a reagent blank will be
analyzed with the curve verification due in March 2017) was received by email on December 2,
2016. No further response is necessary for this Finding.
Comment: The laboratory's reporting limit was not based on the lowest concentration standard
verified. The laboratory was reporting anything less than their permit limit of 28 pg/L as <28 pg/L
rather than reporting down to their lowest calibration verification standard of 25 pg/L. The NC
WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine document states:
The concentrations of the calibration standards must bracket the concentrations of the samples
analyzed. One of the standards must have a concentration equal to or below the lower reporting
concentration for Total Residual Chlorine. The lower reporting limit must be less than or equal to
the permit limit. Example: If the laboratory chooses to have a lower reporting limit of 25 pg/L for
residual chlorine, you must analyze at least a 25 tag/L and report lower concentrations as <25
pg/L. Notification of acceptable corrective action (i.e., a statement that results will be recorded and
reported down to 25 pg/L beginning December 2, 2016 and that the lowest standard analyzed in
subsequent curve verifications will be used for the reporting limit) was received by email on
December 2, 2016. No further response is necessary for this Finding.
pH — Standard Methods, 4500 H+ B-2000 (Aqueous)
Comment: The pH meter calibration time was not being documented. The NC WW/GW LC
Approved Procedure for the Analysis of pH document states: The following must be documented
in indelible ink whenever sample analysis is performed. Meter calibration time(s). Notification of
acceptable corrective action (i.e., a copy of an updated pH calibration log with a column for meter
calibration time that was filled out beginning December 1, 2016) was received by email on
December 5, 2016. No further response is necessary for this Finding.
Comment: The calibration buffers were not clearly identified. The calibration log had a column
titled "Buffers Used" and "4-7-10-8" preprinted in each cell, without specifying whether a two or
three-point calibration was employed and with which buffers. The NC WW/GW LC Approved
Procedure for the Analysis of pH document states: The following must be documented in indelible
ink whenever sample analysis is performed. True values of buffers used for calibration.
Notification of acceptable corrective action (i.e., a copy of an updated pH calibration log with the
column now labeled "Calibration Buffers Used" and "4-7-10" preprinted in each cell, that was
implemented December 1, 2016) was received by email on December 2, 2016. No further
response is necessary for this Finding.
Chlorine, Total Residual — Standard Methods, 4500 Cl G-2000 (Aqueous)
pH — Standard Methods, 4500 H+ B-2000 (Aqueous)
Comment: The benchsheets did not contain units of measure for all analyses. There were no pH
units (i.e., s.u.) on the pH calibration log and the field benchsheet did not have units for the daily
TRC Gel® check standard (i.e., pg/L). North Carolina Administrative Code, 15A NCAC 2H .0805
(g) (1) states: Data pertinent to each analysis must be maintained for five years. The field
benchsheets must provide a space for the signature or initials of the analyst, and proper units of
measure for all analyses. Notification of acceptable corrective action (i.e., submission of the 2016
field benchsheet with pg/L handwritten on the check standards for December and an updated field
benchsheet to be implemented January 2017 with "pg/L" typed in the results column and
submission of the December 2016 pH calibration log and an updated pH calibration log to be
implemented January 2017 with "s.u." handwritten or typed in all pertinent columns) was received
by email on December 2 and 5, 2016. No further response is necessary for this Finding.

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Comment: The pH calibration log and field benchsheet did not contain the facility name. The NC
WW/GW LC Approved Procedure for the Analysis of pH and The NC WW/GW LC Approved
Procedure for the Analysis of Total Residual Chlorine documents state: The following must be
documented in indelible ink whenever sample analysis is performed. Sample site including facility
name and location, ID, etc. Notification of acceptable corrective action (i.e., a copy of the updated
field benchsheet to be implemented January 2017 and the pH calibration log implemented
December 1, 2016 with "City of Kannapolis" on the title heading) was received by email on
December 2, 2016. No further response is necessary for this Finding.
Comment: The pH calibration log and field benchsheet did not contain meter identification. The
NC WW/GW LC Approved Procedure for the Analysis of pH and The NC WW/GW LC Approved
Procedure for the Analysis of Total Residual Chlorine documents state: The following must be
documented in indelible ink whenever sample analysis is performed. Instrument identification.
Notification of acceptable corrective action (i.e., submission of an updated field benchsheet to be
implemented January 2017 with a column to enter the meter identification and an updated pH
calibration log implemented December 1, 2016 which includes a blanket statement that if
instrument #1 is not used, "#2" will be written next to the analyst's initials) was received by email
on December 2, 2016. No further response is necessary for this Finding.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) and contract lab reports to electronic Discharge Monitoring Reports (eDMRs) submitted to
the North Carolina Division of Water Resources. Data were reviewed for City of Kannapolis
(NPDES permit # NC0006220) for January, April and July 2016. No transcription errors were
detected. The facility appears to be doing a good job of accurately transcribing data.
V. CONCLUSIONS:
All Findings noted during the inspection were adequately addressed prior to the completion of
this report. The inspector would like to thank the staff for its assistance during the inspection and
data review process. No response is required.
Report prepared by: Beth Swanson Date: December 5, 2016
Report reviewed by: Anna Ostendorff Date: December 8, 2016