#5481_10_2014_FINAL

A;� NCDENR
Pat McCrary
Governor
November 24, 2014
5481
Mr. Stephen Davis
Shamrock Environmental Corporation
6106 Corporate Park Road
Brown Summit, NC 27214
IMPS11111111110r
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Davis:
Enclosed is a report for the inspection performed on October 29, 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,
Gary Francies, Technical Assistance/Compliance Specialist
Division of Water Resources
Water Sciences Section
NC Wastewater/Groundwater Laboratory Certification Branch
1623 Mall Service Center, Raleigh, North Carolina 27699-1623
Location: 4405 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone]
Internet: www,dWrgfab,o
k equal Opportunity 1 Affirmaliva A(Aw Employaf

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5481
Laboratory Name:
Shamrock Environmental
Inspection Type:
Field Maintenance
Inspector Name(s):
Gary Francies, Beth Swanson
Inspection Date:
October 29, 2014
Date Report Completed:
November 6, 2014
Date Forwarded to Reviewer:
November 6, 2014
Reviewed by:
Gary Francies
Date Review Completed:
11/17/2014
Cover Letter to use:
❑ Insp. Initial ® Insp. Reg.
❑ Insp. No Finding ❑ Insp. CP
❑ Corrected ❑ Insp. Reg. Delay
Unit Supervisor/Chemist III:
Dana Satterwhite
Date Received:
11/17/2014
Date Forwarded to Linda:
11/21/2014
Date Mailed:
\1 I y `� LC_

On -Site Inspection Report
LABORATORY NAME:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
INTRODUCTION:
Shamrock Environmental Corporation
6106 Corporate Park Road
Brown Summit, NC 27214
5481
October 29, 2014
Field Maintenance
Gary Francies and Beth Swanson
Stephen Davis and Jay Gainer
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 maintains voluntary certification. They have never produced certified data for the State of
North Carolina. 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 the inspection.
Proficiency Testing (PT) samples have been analyzed for all certified parameters for the 2014 proficiency
testing calendar year and the graded results were 100% acceptable.
The requirements associated with Findings A, B (i.e., instrument ID) and C have been implemented by
our program since the last inspection.
Ill. . FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Quality Control
A. Finding: The auto-pipettors have not been calibrated annually as required.
Requirement: Mechanical volumetric liquid -dispensing devices (e.g., fixed and adjustable auto-
pipettors, bottle -top dispensers, etc.), used for critical measurements, must be calibrated at
least every twelve months and documented. Each liquid -dispensing device must meet the
manufacturer's statement of accuracy. For variable volume devices used at more than one
setting, check the accuracy at the maximum, middle and minimum values. Testing at more than
three volumes is optional. When a device capable of variable settings is dedicated to dispense
a single specific volume, calibration is required at that setting only. Ref: Quality Assurance
Policies for Field Laboratories.
Comment: An example adjustable pipettor calibration procedure and spreadsheet were
emailed to the laboratory on October 30, 2014.

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#5481 Shamrock Environmental Corporation
B. Finding: The benchsheets do not include instrument IDs or sample time collected/analyzed.
Requirement: The following must be documented in indelible ink whenever sample analysis is
performed: Instrument Identification. Ref: NC WW/GW LC Approved Procedure for the Analysis
of Total Residual Chlorine, NC WW/GW LC Approved Procedure for the Analysis of Dissolved
Oxygen, NC WW/GW LC Approved Procedure for the Analysis of pH.
Requirement: 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 bench sheets must provide a space for the signature or initials of the
analyst, and proper units of measure for all analyses. Ref: 15A NCAC 02H .0805 (g) (1).
C. Finding: The laboratory needs to increase the documentation of purchased materials and
reagents, as well as documentation of standards and reagents prepared in the laboratory.
Requirement: All chemicals, reagents, 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. Ref: Quality Assurance Policies for Field Laboratories.
Comment: The laboratory needs to record the above information for pH buffers, DPD powder,
gel standards and reagents used to prepare the total residual chlorine standards for the annual
curve verification. Laboratory personnel could not verify that non -expired DPD powder was
being used because there was no documentation of traceability and all DPD powder found
during the inspection had exceeded its expiration date.
Comment: An example traceability log is attached to the end of this report. The laboratory may
adopt this form or develop its own.
Proficiency Testing
Comment: The laboratory's common practice was to analyze a known standard along with the PT
sample. Since this would not be performed with any future compliance environmental samples, it is
considered additional quality control. Known samples are only recommended when analyzing remedial
PT samples as part of the troubleshooting and corrective action process.
PH - Standard Methods, 4500 H+ B- 2000
Recommendation: Per the NC WW/GW LC Approved Procedure for the Analysis of pH, instruments are
to be calibrated according to the manufacturer's calibration procedure prior to analysis of samples each
day compliance samples are to be analyzed. The facility calibrates once a month, and did not calibrate on
the day the 2014 PT sample was analyzed. Since the facility does not produce compliance data, this is
not a finding. It is recommended that the pH meter be calibrated immediately prior to analysis of the PT
sample.

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#5481 Shamrock Environmental Corporation
Comment: During the audit, an inspector told the analyst that yearly Automatic Temperature
Compensator (ATC) checks were no longer required, but that the temperature sensor had to be checked
yearly against a National Institute of Standards and Technology traceable thermometer. ATC checks are
indeed not necessary but the comment about checking the temperature sensor was incorrect. Yearly
temperature sensor checks are not required unless the instrument is used to generate temperature data.
Total Residual Chlorine - Standard Methods, 4500 CI G- 2000
D. Finding: The annual calibration curve verification does not bracket the concentration of the
annual PT samples.
Requirement: The concentrations of the calibration standards must bracket the concentrations of
the samples analyzed. One of the standards must have a concentration equal to or below the
lower reporting concentration for Total Residual Chlorine. The lower reporting limit must be less
than or equal to the permit limit. Ref: NC WW/GW LC Approved Procedure for the Analysis of
Total Residual Chlorine.
Comment: The most recent verification that was performed on September 18, 2014 verified the
curve up to 1.0085 mg/L. The most recent PT assigned value was 1.91 mg/L.
E. Finding: The laboratory is not verifying the Gel® Standard every 12 months.
Requirement: Purchased "Gel -type" or sealed liquid ampoule standards may be used for daily
standard curve verification only. These standards must be verified initially and every 12 months
thereafter, with the standard curve. When this is done, these standards may be used after the
manufacturer's expiration date. It is only necessary to verify the gel or sealed liquid standard
which falls within the concentration range of the curve used to measure sample concentrations.
For example, the 0.8 mg/L or 1.5 mg/L Gel® standard. Ref: Approved Procedure for the Analysis
of Total Residual Chlorine.
Comment: The value of the Gel® standard obtained at the time of the 5 point verification, will be
the "true value" used throughout the year and until a new curve is verified.
Comment: Currently, the laboratory only analyzes the yearly PT sample, which is also when the
annual curve verification is performed. Be aware that any time samples are analyzed beyond that
day, it is required that a daily QC check standard (Gel@ standard) be analyzed to check the curve.
The Gel® standard's true value is derived from the value that was obtained on the day of the
annual verification and must check within ± 10%.
F. Finding: The laboratory is not verifying the curve using 5 standards.
Requirement: Analyze a calibration 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 than or equal to 50 µg/L. The overall
correlation coefficient of the curve must be 4.995. Ref: NC WW/GW Approved Procedure for
the Analysis of Total Residual Chlorine.
Comment: The laboratory was only analyzing 4 standards. In addition to the 4 standards, the
curve verification showed 2 zero points that were not clearly identified. It is required that a
calibration blank be analyzed to zero the instrument before any standards, samples, or the

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#5481 Shamrock Environmental Corporation
reagent blank are analyzed. This calibration blank would not create a value. It is also required
that a reagent blank be analyzed any time standards are prepared with reagent water. This
reagent blank value must be recorded and must not exceed 50% of the reporting limit (i.e., the
lowest calibration verification standard).
Dissolved Oxygen - Standard Methods, 4600 O G- 2001
G. Finding: The laboratory could not verify that the meter used for dissolved oxygen analysis was
operable.
Requirement: Each facility must have glassware, chemicals, supplies, equipment, and a source
of distilled or deionized water that will meet the minimum criteria of the approved methodologies.
Ref: 15A NCAC 21-1.0805 (g) (4).
Comment: No samples are currently being analyzed for dissolved oxygen, but in order to retain
certification for this parameter, evidence that the meter is in operable condition must be provided.
IV. PAPER TRAIL INVESTIGATION:
No certified data is produced by the facility, so no paper trail investigation was done.
V. CONCLUSIONS:
Correcting the above citing findings and implementing the recommendation will help this lab be prepared
to analyze environmental samples in the event that it is necessary. The auditors would like to thank the
staff for its assistance during the inspection process. Please respond to all findings.
Report prepared by: Beth Swanson Date: November 6, 2014
Report reviewed by: Gary Francies Date: November 17, 2014

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