#5250_06_2012_FINAL

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #.
5250
Laboratory Name:
Royal Water Works, Inc.
Inspection Type:
Field Commercial Maintenance
Inspector Name(s):
Jason Smith
Inspection Date:
June 13, 2012
Date Report Completed:
July 11, 2012
Date Forwarded to Reviewer: July 20, 2012
Reviewed by:
Jeff Adams
Date Review Completed:
July 20, 2012
Cover Letter to use: _
Insp. Initial X Insp. Reg. _ Insp. No Finding _ Insp. CP _Corrected
Unit Supervisor:
Gary Francies
Date Received:
7/20/2012
Date Forwarded to Linda:
7/24/2012
Date Mailed:
1,25
1 L a

NorthIn
NCDENR
# Department • and Natural Resources
Beverly Eaves Perdue
Governor
5250
Mr. Wesley Royal
Royal Water Works, Inc.
P.O. Box 778
Pisgah Forest, NC 28768
Division of Water Quality
Charles Wakild, P. E.
Director
July 24, 2012
Dee Freeman
Secretary
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Royal:
Enclosed is a report for the inspection performed on June 13, 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,
Gary
Francies
Certification Unit Supervisor
Laboratory Section
Enclosure
Cc: Master File
Jason Smith
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
One
North.Carolina
An Equal Opportunity \ Affirmative Action Employer

LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
INTRODUCTION:
On -Site Inspection Report
Royal Water Works, Inc.
NC0021946, NC0052043, and NCO021733
P.O. Box 778
Pisgah Forest, NC 28768
5250
June 13, 2012
Field Commercial Maintenance
Jason Smith
Wesley Royal and Don Byers
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:
Wesley Royal operates and analyzes samples for Rosman WWTP (NPDES permit # NC0021946) and
Toxaway Falls (NPDES permit #NC0052043). Don Byers operates and analyzes samples for Marshall
WWTP (NPDES permit #NC0021733). However, Mr. Byers stated he intends to obtain laboratory
certification. The laboratory has all the equipment necessary for each analyst to perform the analyses.
The requirements associated with Findings D, E, and F are new policies that have been implemented by
our program since the last inspection.
General Laboratory
A. Finding: Error corrections were not properly performed and some data entry for the Marshall
WWTP was written in pencil.
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.
B. Finding: The DPD powder pillows in use at Toxaway Falls expired in September 2011.
Requirement: Adherence to manufacturer expiration dates is required (except for gel standards
for Total Residual Chlorine). Chemicals, reagents, standards, consumables exceeding the

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#5250 Royal Water Works, Inc.
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.
C. Finding: Data that does not meet all quality control requirements is not qualified on the
Discharge Monitoring Report (DMR).
Requirement: 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
Discharge Monitoring Report (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. Ref: Quality Assurance Policies for Field
Laboratories.
Comment: The laboratory was not transcribing data qualifiers from the contract laboratory reports
to the DMR. The following error was noted: January 3, 2012 Toxaway Falls WWTP BOD result
was not qualified on the Discharge Monitoring Report as reported by Environmental Testing
Solutions (Certified Laboratory #600).
Proficiency Testing
D. Finding: The laboratory is not analyzing Proficiency Testing (PT) samples in the same manner as
environmental samples.
Requirement: All PT samples are to be analyzed and the results reported in a manner consistent
with the routine analysis and reporting requirements of compliance samples and any other
samples analyzed according to the requirements of 15A NCAC 2H .0800. Ref: Proficiency Testing
Requirements, February 20, 2012, Revision 1.2.
Comment: The laboratories common practice was to analyze a known along with the PT sample
as additional Quality Control.
E. Finding: The preparation of Proficiency Testing (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
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.
F. Finding: The laboratory is not documenting Proficiency Testing (PT) sample analyses in the
same manner as environmental samples (i.e. on a laboratory benchsheet or field notebook).

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#5250 Royal Water Works, Inc.
Requirement: All PT sample analyses must be recorded in the daily analysis records as for any
environmental sample. This serves as the permanent laboratory record. Ref: Proficiency Testing
Requirements, February 20, 2012, Revision 1.2.
Documentation
Comment: The documentation at the Marshall WWTP did not include sample collection time, analysis
time, or analyst signature/initials. 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, samples site, sample collector, and sample analysis time. The field
benchsheets must provide a space for the signature of the analyst, and proper units of measure for all
analyses. Demonstration of acceptable corrective action (i.e., a new benchsheet including all required
information) was received by email on June 17, 2012. No further response is necessary for this
finding.
Comment: The pH time of collection and Temperature collection/analysis time was not documented for
the Rosman WWTP. 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, samples site, sample collector, and sample analysis time. The field
benchsheets must provide a space for the signature of the analyst, and proper units of measure for all
analyses. Acceptable corrective action (i.e., updating the benchsheet to include these times) was
performed during the inspection. No further response is necessary for this finding.
Comment: The laboratory did not have a system of traceability for purchased chemicals and reagents.
The Quality Assurance Policies for Field Laboratories 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. 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.
Demonstration of acceptable corrective action (i.e., a traceability log recording all required information)
was received by email on June 25, 2012. No further response is necessary for this finding.
Total Residual Chlorine — Standard Methods, 181h Edition, 4500 Cl G
Comment: The gel standard was analyzed on the regular level (mg/L) curve/program at the Marshall
WWTP. The Technical Assistance for Field Analysis of Total Residual Chlorine states: Calibration checks
must be for the curve and/or program used for sample analysis. Demonstration of acceptable corrective
action (i.e., a new benchsheet indicating checking the gel standard on the low level (,ug/L)
curve/program) was received by email on June 17, 2012. No further response is necessary for this
finding.
Comment: The curve verification for Toxaway Falls was performed on the regular level (mg/L)
curve/program and was last performed in April 2011. The curve verification for Marshall WWTP was not
available at the time of the inspection. The Technical Assistance for Field Analysis of Total Residual
Chlorine document states: Calibration checks must be for the curve and/or program used for sample
analysis. Analyze a water blank to zero the instrument and then analyze a series of five standards. The
curve verification must check 5 concentrations (not counting the blank) that bracket the range of the
samples to be analyzed. This type of curve verification must be performed at. least every 12 months. The
values obtained must not vary by more than 10% of the known value for standard concentrations greater

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#5250 Royal Water Works, Inc.
than or equal to 50 ,ug/L and must not vary by more than 25% of the known value for standard
concentrations less than 50 pg/L. The overall correlation coefficient of the curve must be >_0.995.
Demonstration of acceptable corrective action (i.e., new acceptable curve verifications for both meters)
was received by email on June 25, 2012. No further response is necessary for this finding.
pH — Standard Methods, 181h Edition, 4500 H+ B
Total Residual Chlorine — Standard Methods, 18t" Edition, 4500 Cl G
Comment: The time of pH and Total Residual Chlorine calibration was not documented at the Marshall
WWTP. The Technical Assistance for Field Analysis of pH and Technical Assistance for Field Analysis of
Total Residual Chlorine documents state: Time of calibration must be documented whenever sample
analysis is performed. Demonstration of acceptable corrective action (i.e., a new benchsheet which
includes documentation of calibration times) was received by email on June 17, 2012. No further
response is necessary for this finding.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing 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 January and February, 2012 for Rosman WWTP (NPDES permit #NC0021946), Toxaway
Falls (NPDES permit #NC0052043), and Marshall WWTP (NPDES permit #NC0021733). The following
error was noted:
Date
Parameter
Location
Value on contract
lab report
Value on DMR
2/21/12
BOD
Marshall WWTP Effluent
3.4 mg/L
13 mg/L
2/21/12
TSS
Marshall WWTP Effluent
12 mg/L
21 mg/L
2/21/12
Ammonia
Marshall WWTP Effluent
1.5 mg/L
0.40 mg/L
2/21/12
Fecal Coliform
Marshall WWTP Effluent
2 CFU
44 CFU
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 lab to produce quality data and meet certification
requirements. Please respond to all findings.
Report prepared by: Jason Smith Date: July 11, 2012
Report reviewed by: Jeffrey R. Adams Date: July 20, 2012