#5137 - 04 - 2012 - FINAL

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5137
Laboratory Name:
Town of Elk Park
Inspection Type:
Field Maintenance
Inspector Name(s):
Jason Smith
Inspection Date:
April 17, 2012
Date Report Completed:
May 24, 2012
Date Forwarded to Reviewer: May 24, 2012
Reviewed by:
Jeffrey R. Adams
Date Review Completed:
May 24, 2012
Cover Letter to use: _
Insp. Initial X Insp. Reg. _ Insp. No Finding _ Insp. CP _Corrected
Unit Supervisor:
Gary Francies
Date Received:
5/24/2012
Date Forwarded to Linda:
6/1/2012
Date Mailed:
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Beverly Eaves Perdue Charles Wakild, P. E. Dee Freeman
Governor Director Secretary
June 4, 2012
5137
Mr. Otis Ward
Town of Elk Park
P.O. Box 248
Elk Park, NC 28622
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Ward:
Enclosed is a report for the inspection performed on April 17, 2012 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.
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,
f ✓l am r--a-t.,
Gary Francies
Certification Unit Supervisor
Laboratory Section
Enclosure
cc: Jason Smith
Master file
DENR DWQ 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
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LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
1. INTRODUCTION:
On -Site Inspection Report
Town of Elk Park
NCO079561
P.O. Box 248
Elk Park, NC 28622
5137
April 17, 2012
Field Maintenance
Jason Smith
Otis Ward
This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for
the analysis of environmental samples.
IL GENERAL COMMENTS:
The laboratory has all of the equipment required to perform the analyses. Current Technical Assistance
and Quality Assurance documents were provided at the time of the inspection. Upon request, a new
benchsheet and traceability, log was created to help the laboratory fulfill the requirements. The
requirements associated with Findings A, B, C, and D are new policies that have been implemented by
our program since the last inspection.
III. FINDINGS REQUIREMENTS COMMENTS AND RECOMMENDATIONS:
Documentation
Comment: The laboratory was not aware of the requirement to qualify quality control failures on the
Discharge Monitoring Report (DMR). No instances were observed. This is a new policy that has been
implemented since the last inspection. Quality control failures are mostly associated with contract
laboratory data. The Quality Assurance Policies for Field Laboratories document states: When quality
control (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 DMR form, in the comment section or on a separate sheet attached to
the DMR form, when any required sample quality control does not meet specified criteria and another
sample cannot be obtained.
Comment: The laboratory did not have adequate documentation of purchased materials and reagents.
The Quality Assurances for Field Laboratories document states: All chemicals, reagents, standards and
consumables used by the laboratory must have the following information documented: Date Received,

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#5137 Town of Elk Park
Date Opened (in use), Vendor, Lot Number, and Expiration Date. A system (e.g., traceable identifiers)
must be in place that links standard/reagent preparation information to analytical batches in which the
solutions are used. Documentation of solution preparation must include the analyst's initials, date of
preparation, the volume or weight of standard(s) used, the solvent and final volume of the solution. 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. This is a
new policy that has been implemented by our program since the last inspection. Notification of acceptable
corrective action (i.e., that the traceabilty log provided by this office has been put into use) was received
by email on May 24, 2012. No further response is necessary for this finding.
A. Finding: Error corrections are not dated.
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. Wite-Out®, correction tape or similar products designed to obliterate documentation
are not to be used. Write the correction adjacent to the error. The correction must be initialed
by the responsible individual and the date of change documented. All data and log entries must
be written in indelible ink. Pencil entries are not. acceptable. Ref: Quality Assurance Policies for
Field Laboratories.
Proficiency Testing
B. Finding: Proficiency Testing (PT) samples are not analyzed in the same manner as
environmental samples.
Requirement: The analysis of PT samples is designed to evaluate the entire process used to
routinely report environmental analytical results. Therefore, PT samples must be analyzed and
the process documented in the same manner as environmental samples. Ref: Quality
Assurance Policies for Field Laboratories.
Comment: Analyze PT samples on the same program, using the same procedure that is used
for sample analysis. NPDES samples are analyzed using the Ultra Low Level Total Residual
Chlorine (TRC) (pg/L) internal instrument standard curve; however, PT samples are analyzed
using the Regular Level TRC (mg/L) internal instrument curve.
Recommendation: Regular level PT samples may be diluted so that concentrations are within
the verified (bracketed) curve range. Since the dilution process can introduce additional error, it
is recommended that the facility analyze a low level TRC PT sample. These are currently
available from many vendors.
C. Finding: PT samples are not documented in the same manner as environmental samples (i.e.,
on laboratory benchsheets).
Requirement: The analysis of PT samples is designed to evaluate the entire process used to
routinely report environmental analytical results. Therefore, PT samples must be analyzed and
the process documented in the same manner as environmental samples. Ref: Quality
Assurance Policies for Field Laboratories.
D. Finding: The preparation of PT samples is not documented.
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

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#5137 Town of Elk Park
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.
Temperature — Standard Methods, 18th Edition, 2550 B
Comment: Sample collection/analysis time was not consistently documented. The laboratory benchsheet
did not have space for daily temperature monitoring, so the collection/analysis time was only recorded
one day each week (when analyzed along with pH and Dissolved Oxygen). The rest of the week, only the
sample result was recorded in the operator log book. The North Carolina Administrative Code, 15A
NCAC 2H .0805 (g) (1) states: 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. Notification of acceptable corrective action (i.e., that the
benchsheet provided by this office with enough spaces for daily monitoring of Temperature, and including
all required times, has been put into use) was received by email on May 24, 2012. No further response
is necessary for this finding.
Total Residual Chlorine — Standard Methods, 181h Edition, 4500 CI G
Comment: Sample collection/analysis times, calibration check time, and calibration results were not
consistently documented. Samples were analyzed twice each week, but the laboratory benchsheet only
had space for one analysis per week (when analyzed along with the pH and Dissolved Oxygen). Only the
sample results are documented in the operator log book for the second analysis in the week. The North
Carolina Administrative Code, 15A NCAC 2H .0805 (g) (1) states: 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. The North Carolina Administrative
Code, 15A NCAC 2H .0805 (g) (2) states: A record of instrument calibration where applicable, must be
filed in an orderly manner so as to be readily available for inspection upon request. Notification of
acceptable corrective action (i.e., that the benchsheet provided by this office with enough spaces for twice
per week monitoring of Total Residual Chlorine, and including all cited requirements, has been put into
use) was received by email on May 24, 2012. No further response is necessary for this finding.
E. Finding: Samples were not always analyzed within the EPA holding time.
Requirement: Analyze within 15 minutes. Ref: Code of Federal Regulations, Title 40, Part 136;
Federal Register Vol. 72, No. 47, March 12, 2007; Table II.
Comment: The only example of this that was observed occurred on January 4, 2011. The analyst
stated that he may have been interrupted and called away between collection and analysis. In
instances such as this, another sample must be collected and analyzed rather than analyzing the
sample out of hold.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing laboratory benchsheets and contract lab reports to Discharge
Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data were
reviewed for January, June, and July, 2011. The following error was noted:

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#5137 Town of Elk Park
Date
Parameter
Location
Value on Contract Lab
Report
Value on DMR
1/26/11
Ammonia
Effluent
1.22 mg/L
0.22 mg/L
In order to avoid questions of legality, it is recommended that you contact the appropriate Regional
Office for guidance as to whether an amended Discharge Monitoring Report will be required. A copy of
this report will be forwarded to the Regional Office.
V. CONCLUSIONS:
Correcting the above -cited findings will help this is
Report prepared by: Jason Smith
Report reviewed by: Jeffrey R. Adams
b
Date: May 24, 2012
Date: May 24, 2012