#40_2015

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 bv:
Date Review Completed:
Cover Letter to use:
Unit Supervisor/Chemist III:
Date Received:
Date Forwarded to Linda:
Date Mailed:
40
Pace Analvtical Services Inc — Asheville NC
Maintenance/Abbreviated/Desk Audit
Dana Satterwhite Beth Swanson
11/20/2015 — 12/18/2015
01 /25/2016
01 /26/2016
Gary Francies
1 /26/2016
❑ Insp. Initial
❑ Insp. No Finding
❑ Corrected
® Insp. Reg.
❑ Insp. CP
❑ Insp. Reg. Delay
Dana Satterwhite
1 /26/2016
1 /26/2016
1 /27/2016
Turbidity, Alkalinity, Total Dissolved Residue, Total Suspended Residue, Anions (SO4) and Chloride

Water Resources
ENVIRONMENTAL QUA1_11,V
January 27, 2016
40
Mr. Barry Johnson
PACE Analytical Services, Inc. Asheville
2225 Riverside Drive
Asheville, NC 28804
PAT MCCRORY
DONALD R. VAN DER VAART
S. JAY ZIMMERMAN
w , o,
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Johnson:
Enclosed is a report for the inspection performed on January 26, 2016 by Dana Satterwhite and Beth
Swanson. 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.
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.
Attachment
cc: Jason Smith
Gary Francies
Sincerely, r- �
f Dana Satterwhite
Environmental Program Supervisor III
NC WW/GW Laboratory Certification Branch
Water Sciences Section
NC Wastewater/Groundwater Laboratory Certification Branch
1623 Mail Service Center, Raleigh, North Carolina 27699-1623
Location: 4405 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone]FAX: [phone]
Internet: http://portal.ncdenr.org/web/WQ/lab/cert

LABORATORY NAME:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
INTRODUCTION:
Pace Analytical Services, Inc.
2225 Riverside Drive
Asheville, NC 28804
M
November 20, 2015 — 12/18, 2015
Maintenance/Abbreviated/Desk Audit
Dana Satterwhite, Beth Swanson
Mr. Barry Johnson
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 21-1.0800 for the analysis of environmental samples.
GENERAL COMMENTS:
This was an abbreviated audit performed at the request of the Division of Water Resources and was
limited to data for the following Pace Project Numbers: 92261557, 92265303, 92260963 and 92265356.
The following parameters were reviewed: Turbidity, Alkalinity, Total Dissolved Residue, Total Suspended
Residue, Anions (SO4) and Chloride. The laboratory sent complete data packages which included raw
data [i.e., instrument printouts and/or benchsheets] including associated calibration curves and standard
operating procedures.
Proficiency Testing (PT) samples have been analyzed for all certified parameters. The laboratory has
fulfilled its PT requirements for the 2015 proficiency testing calendar year.
Contracted analyses were performed by Pace Analytical Services, Inc. — Minneapolis, MN (Certification
#530) and Pace Analytical Services, Inc. — Ormond Beach, FL (Certification #667).
The laboratory is reminded that any time changes are made to laboratory operations; the laboratory must
update the Quality Assurance (QA)/Standard Operating Procedures (SOP) document(s). Any changes
made in response to the 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 approved practice and regulatory requirements. In
some instances, the laboratory may need to create a SOP to document how new functions or policy will
be implemented.
FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Standard Operating Procedures (SOPs)
A. Finding: An inconsistency and/or omission was noted between the Standard Operating
Procedure (SOP) and laboratory practice as follows:

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The SOP does not describe in detail how the method is performed.
Alkalinity SM 2320 B 1997 Rev. 2011
SOP# S-ASV-1-002-rev.05 - Title Page and Section 25.4 - The SOP references the 20tn
Edition of Standard Methods for the Examination of Water and Wastewater. The approved
method version with the 2011 editorial revisions appears in the 22"d edition, not the 20tn
edition.
SOP# S-ASV-1-002-rev.05 - Section 12.1.5.5 - The SOP does not state that the volume
of titrant, used to reach the first pH endpoint in the low level procedure, must be recorded.
Total Suspended Residue (TSS) SM 2540 D-1997 Rev. 2011
Total Dissolved Residue (TDS) SM 2540 C-1997 Rev. 2011
SOP# S-CAR-WC-005-rev. 02 - Sections 6.1, 6.2, 12.2 and 13.1 - Evaluate the use of
the word "should". NOTE: It is recommended that all SOPs be reviewed and evaluated for
use of the word "should". SOPs are intended to describe procedures exactly as they are to
be performed.
SOP# S-CAR-WC-005-rev. 02 - Section 9.0, Table 9.1 - It appears that the drying ovens
are listed incorrectly. The VWR oven capable of maintaining a temperature of 103-105°C
is listed for TDS and the Precision oven capable of maintaining a temperature of 178-
182°C is listed for TSS. It appears these are reversed.
SOP# S-CAR-WC-005-rev. 02 - Section 9.0, Table 9.2 - The SOP prescribes: Glass
fiber filters for TDS, TDS, TS. It appears this should read: Glass fiber filters for TDS and
TSS.
SOP# S-CAR-WC-005-rev. 02 - Section 12.1.1 - Please check the volume prescribed for
clean samples (i.e., 50 ml) for accuracy. Based upon Section 5.3 of the SOP, it appears
100 ml may be used for clean samples.
SOP# S-CAR-WC-005-rev. 02 - Section 12.2.1 - The SOP does not prescribe weighing
laboratory -prepared filters to a constant weight or the analysis of a single daily dry filter
blank when pre -weighted filters are used. [Ref: SM 2540 D-1997, Rev. 2011 (3) (a) and
NC WW/GW LC Policy] NOTE: A dry filter blank is included in Section 13.0, Table 13.2 of
the SOP.
SOP# S-CAR-WC-005-rev. 02 - Section 13.0, Table 13.2 - The SOP lists the
acceptance criterion for the Dry Filter Method Blank (MB) as: Within 50% of PRL. It is
unclear what this means since there is no volume of sample used to calculate a TSS
value.
Chloride SM 4500 Cl- E-1997, Rev. 2011
SOP# S-ASV-1-064-rev. 04 - Section 11.0, Table 11.1 - The SOP does not prescribe
back -calculating the concentration of each calibration point. The back -calculated and true
concentrations should agree within ± 10%. [Ref: Standard Methods, 4020 B-2009. (2) (a).]
NOTE: The laboratory may establish acceptance criteria for agreement between the back -
calculated and true values or default to ± 10%.
SOP# S-ASV-1-064-rev. 04 - Section 12.1.2 - The SOP does not prescribe analyzing a
filtered method blank and filtered laboratory fortified blank when samples must be filtered
due to particulates. By definition, method blanks and laboratory fortified blanks must be

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processed through all sample preparation and analysis steps. [Ref: Standard Methods,
1020 B-2011 (5) and (6)]
SOP# S-ASV-1-064-rev. 04 - Section 14.3 - The spike recovery calculation does not take
into account for spike volume when >1% spike to sample volume ratio is used. [Ref: NC
WW/GW LC Policy and Standard Methods 4020 B-2009 (2) (g)]
SOP# S-ASV-1-064-rev. 04 - Section 26.5 - There appears to be a typographical error in
the Lachat Method reference. The correct method number is 10-117-07-1-K.
Fluoride and Sulfate EPA Method 300.0 Revision 2.1 1993
SOP# S-ASV-1-058-Rev. 05 - Section 10, Table 10.1 - There appears to be a
typographical error for the reference to the recipes for preparing dilutions and working
standards, and concentrations for all compounds. The SOP refers to a table in Section
9.2. It appears this table is found in Section 10.2.2.
SOP# S-ASV-1-058-Rev. 05 - Section 12.2.7 - The SOP does not state that quality
control standards and method blanks must also be filtered in the same manner as
samples. [Ref: EPA Method 300.0, Revision 2.1, 1993, Sections 3.5 and 3.7]
Requirement: Each laboratory shall develop and maintain a document outlining the analytical
quality control practices used for the parameters included in their certification. Supporting records
shall be maintained as evidence that these practices are being effectively carried out. Ref: 15A
NCAC 2H .0805 (a) (7). Please submit updated SOPs with the items listed above addressed
by April 30, 2016.
General Quality Control
B. Finding: The laboratory is not documenting the true value and percent recovery of quality
control standards on laboratory benchsheets (e.g., TSS, TDS and Turbidity).
Requirement: Each laboratory shall develop and maintain a document outlining the analytical
quality control practices used for the parameters included in their certification. Supporting records
shall be maintained as evidence that these practices are being effectively carried out. Ref: 15A
NCAC 2H .0805 (a) (7).
Requirement: Any time quality control results indicate an analytical problem, the problem must be
resolved and any samples involved must be rerun if the holding time has not expired. Ref: 15A
NCAC 211-1.0805 (a) (7) (F).
Comment: The true value of quality control samples and percent recovery obtained must be
documented on the benchsheet and evaluated against established acceptance criteria to
demonstrate that the analyst was aware of any out -of -control situation. The corrective actions
taken must be documented. Any samples not meeting the acceptance criteria must be
reanalyzed, if possible. If this is not possible, the data must be flagged on the laboratory reports
as all quality control requirements not met. This requirement also applies to both precision and
accuracy of matrix spikes.
Alkalinity - Standard Methods 2320 B-1997 rev. 2011
C. Finding: The laboratory is not calculating spike recovery properly.

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Requirement: The volume of spike solution used in matrix spike preparation must in all cases
be 5 10% of the total matrix spike volume. It is preferable that the spike solution constitutes s
1 % of the total matrix spike volume so that the matrix spike can be considered a whole volume
sample with no adjustment by calculation necessary. If the spike solution volume constitutes
>1% of the total sample volume the sample concentration or spike concentration must be
adjusted by calculation. Ref: NC WW/GW LC Policy.
Comment: The spike solution volume constitutes >1 % of the total sample volume when
preparing matrix spikes and the laboratory is not using the proper correction factor when
calculating the final result. The laboratory is currently preparing LFMs with 5% spike volume.
The SOP matrix spike calculation does not account for sample dilution by the spiking solution.
D. Finding: The units of measure for pH (i.e., s.u.) are not documented on the benchsheets.
Requirement: All laboratories must use printed laboratory bench worksheets that include a
space to enter the signature or initials of the analyst, date of analyses, sample identification,
volume of sample analyzed, value from the measurement system, factor and final value to be
reported and each item must be recorded each time samples are analyzed. The date and time
BOD and coliform samples are removed from the incubator must be included on the laboratory
worksheet. Ref: 15A NCAC 2H .0805 (a) (7) (H).
Total Suspended Residue -*Standard Methods 2540 D 1997 Rev. 2011
Total Dissolved Residue - Standard Methods 2540 C-1997 Rev. 2011
E. Finding: The units of measure for sample and beaker weights are not documented on the
benchsheets.
Requirement: All laboratories must use printed laboratory bench worksheets that include a
space to enter the signature or initials of the analyst, date of analyses, sample identification,
volume of sample analyzed, value from the measurement system, factor and final value to be
reported and each item must be recorded each time samples are analyzed. The date and time
BOD and coliform samples are removed from the incubator must be included on the laboratory
worksheet. Ref: 15A NCAC 2H .0805 (a) (7) (H).
Chloride - Standard Methods 4500 CI- E-1997 Rev. 2011
F. Finding: The laboratory is not calculating spike recovery properly.
Requirement: The volume of spike solution used in matrix spike preparation must in all cases
be <- 10% of the total matrix spike volume. It is preferable that the spike solution constitutes 5
1 % of the total matrix spike volume so that the matrix spike can be considered a whole volume
sample with no adjustment by calculation necessary. If the spike solution volume constitutes
>1 % of the total sample volume the sample concentration or spike concentration must be
adjusted by calculation. Ref: NC WW/GW LC Policy.
Comment: The spike solution volume constitutes >1% of the total sample volume when
preparing matrix spikes and the laboratory is not using the proper correction factor when
calculating the final result. The laboratory is currently preparing LFMs with 2% spike volume.
The SOP matrix spike calculation does not account for sample dilution by the spiking solution.

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IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks, chain -
of -custody forms, etc.) and client reports. Data were reviewed for the following Pace Project Numbers:
92261557, 92265303, 92260963 and 92265356. 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 recommendations will help this lab to
produce quality data and meet certification requirements. The inspector would like to thank the staff for
its assistance during the inspection. Please respond to all Findings and include an implementation
date for each corrective action.
Report prepared by: Dana Satterwhite Date: 1/25/2016
Report reviewed by: Gary Francies Date: 1/26/2016