#5432_11_2014_FINAL

North -A
01 10A
RUDER
• Department Environment • ti Natural Resources
Pat McCrory
Governor
November 24, 2014
5432
Ms. Barbara Auman
Auman Mobile Home Park, LLC
3910 - 2 N Main St.
High Point, NC 27265
John E, Skvarla, III
Secretary
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Ms. Auman:
Enclosed is a report for the inspection performed on November 4, 2014 by Beth Swanson and
myself. 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.
Attachment
cc: Beth Swanson
Master File
Sincerely,
COY
Gary Francies, Technical Assistance/Compliance Specialist
Division of Water Resources
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: www.dwglab.org
An Equal OpportunitytAtfirmative Action Employer

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 Linda:
Date Mailed:
5432
Auman Mobile Home Park, LLC
Field Maintenance
Beth Swanson and Gary Francies
November 4, 2014
November 17. 2014
November 17, 2014
Todd Crawford
November 17, 2014
❑ Insp. Initial ® Insp. Reg.
❑ Insp. No Finding ❑ Insp. CP
❑ Corrected ❑ Insp. Reg. Delay
Gary Francies
11 /18/2014
11 /21/2014
kkI-A(Lq

On -Site Inspection Report
LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
INTRODUCTION:
Auman Mobile Home Park, LLC
NCO055212
3910 - 2 N Main St.
High Point, NC 27265
5432
November 4, 2014
Field Maintenance
Beth Swanson and Gary Francies
Barbara Auman and Bo Einig
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 facility has all the equipment to perform the analyses. Additional analyses are performed by
Research & Analytical Laboratories (Certification #34).
Current quality assurance policies for Field Laboratories and approved procedures for the analysis of the
facility's currently certified parameters were provided at the time of inspection.
The requirements associated with Findings B, E, G and H have been implemented by our program since
the last inspection.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
Comment: The combined benchsheet for pH, Temperature and Dissolved Oxygen used by the facility
was lacking instrument ID. The NC WW/GW LC Approved Procedure for the Analysis of Dissolved
Oxygen, NC WW/GW LC Approved Procedure for the Analysis of pH and NC WW/GW LC Approved
Procedure for the Analysis of Temperature documents state: The following must be documented in
indelible ink whenever sample analysis is performed: Instrument Identification. Notification of
acceptable corrective action (i.e., a statement that a revised benchsheet showing the instrument ID had
been put into use on November 11, 2014) was received via a phone conversation on November 12, 2014.
No further response is necessary for this finding.

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#5432 Auman Mobile Home Park, LLC
A. Finding: All original records were not on file.
Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A NCAC
2H .0805 (g) (1).
Comment: Stream testing data is initially written on a piece of paper, transferred to a steno
notebook, and then brought back to the office to be transferred to the daily benchsheet. The
original paperwork is then discarded. Original observations must be maintained so that the
accuracy of data transcription can be verified.
B. Finding: The laboratory needs to increase the documentation of purchased materials.
Requirement: All 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. Ref: Quality Assurance Policies for Field Laboratories.
Comment: An updated benchsheet with a space for pH buffer lot number and expiration date was
provided by email to the laboratory on November 5, 2014.
Recommendation: It is recommended that the date the bottle was opened be written on the
paper inserts that come with the buffer solutions to satisfy the rest of the documentation
requirements. The inserts would then be stored with all other required documentation for a period
of five years.
D. Finding: Error corrections are not performed properly.
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.
Comment: An instance of using Wite-Out® correction fluid was found on the Discharge
Monitoring Report (DMR) for January 30, 2014.
PH - Standard Methods, 4500 H+B-2000
Comment: A post analysis check standard is not required since pH is only performed at the facility's
primary location.
Comment: The temperature. sensor on the pH meter does not need to be verified since that meter is not
currently used to obtain temperature compliance data; the Dissolved Oxygen meter is used.

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#5432 Auman Mobile Home Park, LLC
E. Finding: Values were reported that exceed the method specified accuracy of 0.1 units.
Requirement: By careful use of a laboratory pH meter with good electrodes, a precision of
±0.02 unit and an accuracy of ±0.05 unit can be achieved. However, ± 0.1 pH unit represents
the limit of accuracy under normal conditions, especially for measurement of water and poorly
buffered solutions. For this reason, report PH values to the nearest 0.1 pH unit. Ref: Standard
Methods, 4500 H+ B-2000, (6).
F. Finding: Sample collection and/or analysis time is not documented correctly.
Requirement: The following must be documented in indelible ink whenever sample analysis is
performed: Date and time of sample collection; Date and time of sample analysis to verify the
15 minute holding time is met. Alternatively, one time may be documented for collection and
analysis with the notation that samples are measured in situ or immediately at the sample site.
Ref: NC WW/GW LC Approved Procedure for the Analysis of pH.
Comment: On numerous instances, it was noted that the benchsheets listed an "analysis time"
that occurred before "collection time". This was likely an error in filling out the benchsheet. Since
pH is analyzed at the sample site, the collection and analysis time can be considered the same
time. A revised benchsheet provided to the facility has one column designated "Time" that should
prevent confusion.
Proficiency Testing
G. Finding: The laboratory is not documenting Proficiency Testing (PT) sample analyses in the
same manner as environmental samples.
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.
Comment: The PT result is not being recorded on the facility's benchsheet and retained. It is
written on the side of the PT sample bottle and discarded.
H. 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 laboratory's common practice was to analyze a known standard along with the PT
sample. Since this is not performed with all environmental samples, it is considered additional
quality control. However, known samples are recommended when analyzing remedial PT samples
as part of the troubleshooting and corrective action process.

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#5432 Auman Mobile Home Park, LLC
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 Resources. Data were
reviewed for January, May and August, 2014. The following errors were noted:
Date
Parameter
Location
Value on
Benchsheet
Value on
DMR
1/16/14
Temperature
Effluent
4.0 °C
4.1 °C
1/16/14
Temperature
Upstream
3.1 °C
3.0°C
1/23/14
Dissolved Oxygen
Upstream
12.92 mg/L
12.94 mg/L
1/30/14
Dissolved Oxygen
Effluent
12.53 mg/L
14.22 mg/L
5/7/14
Dissolved Oxygen
Effluent
8.76 mg/L
11.25 mg/L
5/15/14
pH
Effluent
5/15/14
Dissolved Oxygen
Effluent
7.97 mg/L
7.98 mg/L
5/15/14
Dissolved Oxygen
Upstream
9.98 mg/L
9.62 mg/L
5/15/14
Dissolved Oxygen
Downstream
9.87 mg/L
9.57 mg/L
8/13/14
Dissolved Oxygen
Upstream
7.87 mg/L
7.89 mg/L
8/13/14
Dissolved Oxygen
Downstream
9.94 mg/L
7.94 mg/L
*pH data analyzed on this day was recorded on the DMR on 5/21/14
Comment: There were no analyses documented on the benchsheet for 5/21/14, however values were
reported for that date on the DMR. This is when it was discovered that the benchsheet was not the
original record. See Finding A above.
Comment: Effluent data analyzed on 5/28/14 was reported as being analyzed on 5/27/14.
Recommendation: Due to the number of errors noted in the paper trail investigation it is recommended
that a system of checking the data entered on the DMR be implemented. It would be beneficial to have a
second person review the accuracy of data transcription to the DMR. At a minimum, the person entering
the data should review the transcriptions to the DMR after some time has passed from the original data
entry. In order to avoid questions of legality, it is recommended that you contact the appropriate Regional
Office for guidance as to whether amended DMRs will be required. A copy of this report will be made
available to the Regional Office.
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: Beth Swanson Date: November 17, 2014
Report reviewed by: Todd Crawford Date: November 17, 2014