#55_06_2012_FINAL

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
55
Laboratory Name:
High Point Central Lab Services
Inspection Type:
Municipal Maintenance
Inspector Name(s):
Jason Smith, Chet Whiting, Jeff Adams
Inspection Date:
June 26, 2012
Date Report Completed:
July 20, 2012
Date Forwarded to Reviewer: July 20, 2012
Reviewed by:
Chet Whiting
Date Review Completed:
July 27, 2012
Cover Letter to use: e
Insp. Initial X Insp. Reg. _ Insp. No Finding _ Insp. CP _Corrected
Unit Supervisor:
Gary Francies
Date Received:
7/27/2012
Date Forwarded to Linda:
8/2/2012
Date Mailed:
%I
`l i IQ,

4 d e
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P. E. Dee Freeman
Governor Director Secretary
August 6, 2012
55
Ms. Dawn Molnar
High Point Central Lab Services
P.O. Box 230
High Point, NC 27261-0230
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW
LC) Maintenance Inspection
Dear Ms. Molnar:
Enclosed is a report for the inspection performed on June 26, 2012 by Jason Smith, Chet
Whiting and Jeff Adams. I apologize for the delay in getting this report to you. 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. 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 us at
828-296-4677.
Sincerely,
Gary Francies
Certification Unit Supervisor
Laboratory Section
Enclosure
cc: Jason Smith
Master File
DENR DWO Laboratory Section NC Wastewater/Groundwater Laboratory Certification Branch
1623 Mail Service Center, Raleigh, North Carolina 27699-1623
Location: 4405 Reedy Creek Road. Raleigh, North Carolina 27607-6445
Phone: [phone] \ FAX: [phone]
Internet: www.dwglab.org
An Equal Opportunity \ Affirmative Action Employer

On -Site Inspection Report
LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
I i! k t Zs7111Lei ILeiId
High Point Central Lab Services
NCO024228 and NCO024210
P.O. Box 230
High Point, NC 27261-0230
55
June 26, 2012
Municipal Maintenance
Jason Smith, Chet Whiting, and Jeff Adams
Dawn Molnar and Bill Frazier
This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for
the analysis of environmental samples.
II. GENERAL COMMENTS:
The lab was clean and well organized. All the equipment necessary to perform the certified analyses was
present and appeared well maintained. The system for traceability is effective, thorough and easy to
follow. Laboratory personnel communicate well with sample collectors and coordinate sample analyses
effectively to manage workload and holding times. With few exceptions, laboratory personnel have done
an excellent job of keeping up with changes in North Carolina Wastewater/Groundwater Laboratory
Certification Policy. The requirements associated with Findings A, B, C, D, and F are new policies that
have been implemented by our program since the last inspection.
On May 18, 2012, EPA promulgated changes to the list of Clean Water Act (CWA) methods at 40 CFR
Part 136.3. This action, referred to as the Methods Update Rule (MUR) approves new methods, or
changes to existing methods, that affects over 100 EPA methods, Standard Methods, ASTM methods,
and other test procedures in Part 136 of Title 40 of the Code of Federal Regulations (CFR). The rule also
contains a number of clarifications relating to approved methods, sample preservation and holding times,
and method modifications. The final rule may be found at:
http://water.epa.gov/scitech/methods/cwa/update index.cfm. The North Carolina Wastewater/
Groundwater Laboratory Certification (NC WW/GW LC) program will be asking certified laboratories to
move toward implementation of the new rule with changes fully implemented by the end of 2012. Each
laboratory will need to review the MUR and evaluate its effect on current laboratory practices. These
changes must be made in the laboratory's Standard Operating Procedures and in Quality Manuals, as
well as any other place where the method is cited, e.g., reports, benchsheets, logs, etc. During this
transition period, inspection reports will refer to the methods employed at the laboratory at the time of the
inspection, but will reference the requirements in the most recently approved version of the method. Any
difficulties encountered with meeting the requirements of these references by the date due may be
addressed in the written corrective action response.

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III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
General Laboratory
A. Finding: Samples are not chemically preserved within 15 minutes of collection.
Requirement: Except where noted in this Table II and the method for the parameter, preserve
each grab sample within 15 minutes of collection. For a composite sample collected with an
automated sample (e.g., using a 24-hour composite sample; see 40 CFR 122.21(g)(7)(i) or 40
CFR Part 403, Appendix E), refrigerate the sample at _< 6 °C during collection unless specified
otherwise in this Table II or in the method(s). For a composite sample to be split into separate
aliquots for preservation and/or analysis, maintain the sample at <_ 6 °C, unless specified
otherwise in this Table II or in the method(s), until collection, splitting, and preservation is
completed. Add the preservative to the sample container prior to sample collection when the
preservative will not compromise the integrity of a grab sample, a composite sample, or aliquot
split from a composite sample within 15 minutes of collection. Ref: Ref: Code of Federal
Regulations, Title 40, Part 136; Federal Register Vol. 77, No. 97, May 18, 2012; Table 11, Footnote
2.
B. Finding: Auto-pipettors are only calibrated once each year.
Requirement: Mechanical volumetric liquid -dispensing devices (e.g., fixed and adjustable auto-
pipettors, bottle -top dispensers, etc.) must be calibrated at least twice per year, approximately
six months apart and documented. Each liquid -dispensing device must meet the manufacturer's
statement of accuracy. Ref: North Carolina Wastewater/Groundwater Laboratory Certification
Policy.
Documentation
Recommendation: Nutrient and metals results are reported to three decimal places by the instruments.
The analyst then crosses out the result and rounds it to two decimal places. Although this is not a true
error correction, the manner in which it is performed makes it appear to be an error correction that is not
performed according to Laboratory Certification Policy. It is recommended that the original printout result
not be marked out in order to avoid this confusion. The reported result should still be written beside the
printout result.
Proficiency Testing
C. Finding: The laboratory does not have Standard Operating Procedures (SOP) for Proficiency
Testing (PT) samples.
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: Laboratories must have a documented plan (this is usually detailed in the
laboratory's Quality Assurance Manual) of how they intend to cover the applicable program
requirements for proficiency testing per their scope of accreditation. This plan shall cover any
commercially available proficiency testing and any inter -laboratory organized studies, as
applicable. The laboratory must also be able to explain when proficiency testing is not possible for
certain parameters and provide a description of what the laboratory is doing in lieu of proficiency
testing. This shall be detailed in the plan. The plan must also address the laboratory's process for

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#55 High Point Central Lab Services
submission of proficiency testing results and related corrective action responses. Laboratory
Standard Operating Procedures (SOPs) must address how low level samples will be analyzed,
including concentration of the sample or adjustment of the normality of a titrant. These instructions
shall be followed when the concentration of a PT sample falls below the range of their routine
analytical method. Instructions shall also be included in the laboratory's SOP for how high level
samples will be analyzed, including preparation of multiple dilutions of the sample. These
instructions will be followed when the concentration of a PT falls above the range of their routine
analytical method. Ref: Proficiency Testing Requirements, February 20, 2012, Revision 1.2.
Biochemical Oxygen Demand (BOD) — Standard Methods, 20th Edition, 5210 B
D. Finding: Blanks are not documented to two decimal places in order to demonstrate that the
Dissolved Oxygen (DO) uptake is <_ 0.20 mg/L.
Requirement: With each batch of samples incubate one or more bottles of dilution water that
contains nutrient mineral, and buffer solutions, but no seed or nitrification inhibitor. The DO uptake
in 5 days must not be more than 0.20 mg/L. Ref: Standard Methods, 5210 B-2001 B. (6) (c).
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. The quality
control document shall be available for inspection by the State Laboratory. Ref: 15A NCAC 2H
.0805 (a) (7).
Total Suspended Solids — Standard Methods, 215t Edition, 2540 D
E. Finding: The samples are not weighed to constant weight, nor is an annual multiple weighing
study to verify the adequacy of the drying time, performed.
Requirement: Constant weights must be documented. The approved methods require the
following: "Repeat the cycle of drying, cooling, desiccating, and weighing until a constant weight
is obtained or until the weight change is less than 4% of the previous weight or 0.5 mg,
whichever is less." In lieu of this, an annual study documenting the time required to dry
representative samples to a constant weight may be performed. Verify minimum daily drying
time is greater than or equal to the time used for the initial verification study drying cycle. Drying
cycles must be a minimum 1 hour for verification. Ref: North Carolina Wastewater/Groundwater
Laboratory Certification Policy based on Standard Methods 20th Edition, 2540 D. (3) (c), 2540 B.
(3) (b), and 2540 C. (3) (d).
Comment: North Carolina allows for an annual drying study in lieu of the requirement above to
repeat the drying cycle for every sample. A random full set of samples should be used for the
drying study. The repeated drying time in the oven should be at least 1 hour long. The time
used for the annual drying study is the minimum time that samples are to be dried until a new
drying study is performed.
Comment: The laboratory misunderstood the different requirements for demonstrating constant
weight prior to analysis and after analysis. The annual drying study has been performed in the
past, but was no longer performed when a daily dry filter blank was implemented.

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Cyanide — Lachat Method 10-204-00-1-X
Total Phosphorus — Standard Methods, 215t Edition, 4500 P F
Recommendation: The current held curve consists of five standard points, however it is is a non -linear
quadratic (second order) curve. It is recommended that six standards be used for quadratic curves, or if
possible, continue using five standards and calculate as a linear curve.
Metals — Standard Methods, 3111 B
Metals — Standard Methods, 3113 B
Recommendation: It is recommended that the laboratory rotate the position of samples, blanks and
quality control samples in the block digester. Random placement will help to identify whenoptimal
performance is not achieved in an individual sample well. It is also recommended that the laboratory
implement a temperature grid check of the block digester by alternating the well location of the
thermometer each time samples are digested. This will document heating uniformity and consistency of
all sample wells in the block.
F. Finding: The blank acceptance criterion is "less than" the reporting limit. Also the blank is not
calculated in order to demonstrate that it is less than half of the reporting limit.
Requirement: For analyses requiring a calibration curve, the concentration of method and
reagent blanks must not exceed 50% of the reporting limit, unless otherwise specified by the
reference method. Ref: North Carolina Wastewater/Groundwater Laboratory Certification
Policy.
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. The quality
control document shall be available for inspection by the State Laboratory. Ref: 15A NCAC 2H
.0805 (a) (7).
Comment: The blank must be calculated in order to demonstrate that it is less than half of the
reporting limit.
Comment: This policy applies to all methods, not just metals.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing laboratory benchsheets, field testing records, and contract lab
reports to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water
Quality. Data were reviewed for High Point Westside WWTP (NPDES permit #NC0024228) and High
Point Eastside WWTP (NPDES permit #NC0024210) for March and April, 2012. 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 and data review process. Please respond to all findings.
Report prepared by: Jason Smith Date: July 20, 2012
Report reviewed by: Chet Whiting Date: July 27, 2012