#5412_01_2014_FINAL

-A
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Qualify Programs
Thomas A. Reeder
Director
February 26, 2014
5412
Mr. Bobby Sisk
Town of Walnut Cove
P.O. Box 734
Walnut Cove, NC 27052
John E. Skvarla, III
Secretary
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Bobby Sisk:
Enclosed is a report for the inspection performed on January 28, 2014 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
[phone].
Sincerely,
Gary Francies
Technical Assistance/Compliance Specialist
Laboratory Section
Enclosure
cc: Master File, Jason Smith
DENR DWR VVQP 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 27607-8445
Phone: [phone]FAX: [phone]
Internet: www.dwglab.org
An Eauai Opperiumty', Affirmative 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:
5412
Town of Walnut Cove
Field Maintenance
Jason Smith
January 28, 2014
February 13. 2014
February 17, 2014
Nick Jones
February 19, 2014
❑ Insp. Initial ® Insp. Reg.
❑ Insp. No Finding ❑ Insp. CP
❑ Corrected
Gary Francies
February 19, 2014
2/26/2014
2/26/14 Ic

LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
I. INTRODUCTION:
On -Site Inspection Report
Town of Walnut Cove
NCO025526
P.O. Box 734
Walnut Cove, NC 27052
5412
January 28, 2014
Field Maintenance
Jason Smith
Bobby Sisk
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.
GENERAL COMMENTS:
The facility has all the equipment necessary to perform the analyses. During the inspection, the laboratory
changed their contact and supervisor from Mark Bowman to Bobby Sisk, who is the current Operator in
Responsible Charge (ORC).
Proficiency Testing (PT) samples have been analyzed for all certified parameters for the 2013 proficiency
testing calendar year and the graded results were 100% acceptable.
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.
Contracted analyses are performed by Pace Analytical Services, Inc. - Eden (Certification #633).
The requirements associated with Findings A, B, C, F, G, H, I, and J have been implemented by our
program since the last inspection.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
A. 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.

Page 2
#5412 Town of Walnut Cove
B. Finding: The laboratory needs to increase the documentation of purchased materials and
reagents.
Requirement: 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. Ref: Quality Assurance Policies for Field
Laboratories.
Comment: An example traceability log was faxed to the facility on February 10, 2014.
Implementation of this log will fulfill this requirement.
C. Finding: Instrument identification is not documented on the benchsheets for Total Residual
Chorine, Dissolved Oxygen, Temperature and pH.
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 Temperature, and NC
WW/GW LC Approved Procedure for the Analysis of pH.
Comment: A new benchsheet including spaces to list instrument ID was faxed to the laboratory
on February 10, 2014. Implementation of this benchsheet will fulfill this requirement.
D. 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. For example, the contract lab reported a data qualifier indicating that the
Glucose/Glutamic Acid was not within the acceptable range of 198 ± 30.5 m/L on the final report
for the March 26, 2013 Effluent Biochemical Oxygen Demand (BOD) sample. No qualifier was
documented on the DMR.
E. Finding: Data is not properly recorded on the DMR.

Page 3
#5412 Town of Walnut Cove
Requirement: Use of "less than" values. For calculation purposes only, recorded values of less
than a detectable limit (< #.##) may be considered to equal zero (0) for all parameters except
Fecal Coliform, for which values of "less than" may be considered to be equal to one (1). Values
of results which are less than a detectable limit should be reported in the daily cells using the "less
than" symbol (<) and the detectable limit used during the testing (or the value with appropriate unit
conversion). Please note there is never a case when an average would need to be recorded along
with a "less than" symbol. Ref: "Directions for Completing Monthly Discharge Monitoring Reports".
Comment: Results reported by the contract laboratory as "NU were reported as "ND" on the
DMR. Instead of doing this, the laboratory must report the value as less than the reporting limit
listed by the contract laboratory. For example, if the contract laboratory's reporting limit for (BOD)
is listed as 2 mg/L, report the result as <2 mg/L.
Comment: The laboratory reports Total Residual Chlorine (TRC) results down to 0 pg/L. The
reporting limit for TRC is determined by the lowest concentration verified during the annual curve
verification, which was 25 lag/L the last time this was performed in 2013. So TRC results below 25
lag/L must be reported as <25 lag/L.
Quality Assurance
F. Finding: The automatic pipettor has not been calibrated annually.
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: The automatic pipettor is used to pipet liquid reagents for Total Residual Chlorine
(TRC) analyses. However, since this is not considered a critical measurement, calibration is not
required when used only for this purpose.
Recommendation: Since the automatic pipettor is used once each year to prepare the TRC
Proficiency Testing (PT) sample; which is considered a critical measurement, it is recommended
that this calibration be performed just before PT sample preparation.
Comment: Purchasing and using a glass volumetric pipet for PT preparation as an alternative to
this calibration was discussed during the inspection. Doing this would also be an acceptable
response to this Finding. Please be sure to confirm the correct volume needed before purchasing
the volumetric pipet.
Proficiency Testing
G. Finding: The laboratory is not documenting 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.

Page 4
#5412 Town of Walnut Cove
Comment: This means that the PT analyses must be documented on a benchsheet in the
same manner as daily samples.
H. Finding: The laboratory is analyzing additional quality control samples with the PT.
Requirement: Laboratories shall conduct proficiency tests in accordance with their routine
testing, calibration and reporting procedures, unless otherwise specified in the instructions
supplied by the PT provider. They shall not be analyzed with additional quality control or replicated
beyond what is routine for environmental sample analysis. Ref: Proficiency Testing
Requirements, February 20, 2012, Revision 1.2.
Comment: The laboratory analyzes a known sample along with the PT. 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.
Finding: The laboratory is analyzing PT samples multiple times.
Requirement: Laboratories shall conduct proficiency tests in accordance with their routine
testing, calibration and reporting procedures, unless otherwise specified in the instructions
supplied by the PT provider. They shall not be analyzed with additional quality control or replicated
beyond what is routine for environmental sample analysis. Ref: Proficiency Testing
Requirements, February 20, 2012, Revision 1.2.
J. 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
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.
Comment: Retaining the PT sample instruction sheet from the vendor signed and dated by the
technician will satisfy this requirement.
pH — Standard Methods 4500 H+ B-2000
K. Finding: Units of measure are not documented on the benchsheet.
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 benchsheets must provide a space for the signature or initials of the analyst, and
proper units of measure for all analyses. Ref: 15A NCAC 2H .0805 (g) (1).
Comment: Proper units of measure for pH are Standard Units (S.U.). A new benchsheet
including pH units of measure was faxed to the laboratory on February 10, 2014. Implementation
of this benchsheet will fulfill this requirement.
L. Finding: A check standard was not analyzed after meter calibration.
Requirement: In addition to the calibration buffers, the meter calibration. must be verified with a
third standard buffer solution. Ref: NC WW/GW LC Approved Procedure for the Analysis of pH.

Page 5
#5412 Town of Walnut Cove
Comment: The analyst records the value of each buffer during the calibration of the meter.
However, this may not represent the value obtained after calibration is complete.
Comment: After the meter reports the calibration slope, analyze the 7 S.U. buffer and record the
value obtained. The result must be ± 0.1 S.U. of the true value of the buffer (i.e., 6.9-7.1 S.U.).
Temperature — Standard Methods 2550 B-2000
M. Finding: Temperature samples are not analyzed within the EPA approved holding time.
Requirement: Temperature — Maximum holding time: Analyze. Ref: Code of Federal Regulation
Title 40, Part 136; Federal Register Vol. 77, No. 97, May 18, 2012; Table II.
Requirement: Immediate (i.e., in situ) analysis is required. Ref: NC WW/GW LC Approved
Procedure for the Analysis of Temperature.
Recommendation: It is recommended that the laboratory purchase a traceable thermometer to
analyze temperature in situ since none of the meters in use are portable. These traceable
thermometers are relatively inexpensive, but must be either recalibrated or replaced by the
expiration date provided by the manufacturer.
Comment: The bench top meters are no longer required to have their temperature sensors
checked annually since this is only required for meters used to report temperature results.
Total Residual Chlorine — Standard Methods 4600 Cl G-2000
Comment: The laboratory is currently using liquid reagents and a flow -through cell for sample analysis.
This is acceptable; however, the laboratory may choose to use powdered DPD and discontinue the use of
the liquid reagents and flow -through cell in order to improve efficiency and reduce costs. Please note that
a new curve verification, using the powdered DPD and/or a sample cuvette, instead of the flow -through
cell, will have to be performed prior to implementing this change. Since a new curve verification is
required by the Finding below, this would be a good time to implement this change.
N. Finding: The calibration curve is not verified each day.
Requirement: When a five -standard annual standard curve verification is used, the laboratory
must check the calibration curve each analysis day. To do this, the laboratory must analyze a
calibration blank to zero the instrument and analyze a check standard each day that samples are
analyzed. The value obtained for the check standard must read within 10% of the true value of the
check standard. If the obtained value is outside of the ±10% range, corrective action must be
taken. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine.
Recommendation: It is recommended that the daily curve verification be performed using gel
standards. Once purchased, the requirement for beginning to use the gel standard is as follows:
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, if you are
measuring samples against a low range curve, a 200 lag/L standard would be verified, and not the
800 lag/L standard since the 800 lag/L standard would be measured using a high range curve.

IV.
Page 6
#5412 Town of Walnut Cove
Immediately following curve verification:
1. Zero the instrument with the gel blank.
2. Read and record gel standard values.
3. Assign the obtained values as the true value.
The assigned values will be used for the next twelve months, or until a new curve verification is
performed. The gel/liquid standard verification must be performed for each instrument on which
they are to be used. If multiple instruments and/or standard sets are used, each must have
assigned values specific for the instrument and standard set. Documentation must link the gel
standard identification to the meter with which the assigned value was determined. Some
commercial laboratory facilities may be able to provide assistance with the field photometric meter
curve verifications.
Comment: The time of curve verification (gel standard analysis) must also be recorded.
O. Finding: The annual curve verification performed by the contract lab was not acceptable.
Requirement: Annual Factory -set Standard Curve Verification: Analyze a calibration blank to
zero the instrument and then analyze a series of five standards (do not use gel or sealed liquid
standards for this purpose). The curve verification must check 5 concentrations (not counting the
blank) that bracket the range of the sample concentrations to be analyzed. This type of standard
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
ug/L and must not vary by more than 25% of the known value for standard concentrations less
than 50 ug/L. The overall correlation coefficient of the curve must be >_0.995. Ref: NC WW/GW
LC Approved Procedure for the Analysis of Total Residual Chlorine. Please submit an
acceptable TRC curve verification with the reply to this report.
Comment: The 100 pg/L standard read 111 pg/L, which is >10% of the true value and
unacceptable. Also, the 500 pg/L standard was above the range of the meter and did not provide
a reading resulting in only four concentrations being verified. In order to avoid this, it is
recommended that the highest concentration be 400 pg/L.
Recommendation: It is recommended that the following concentrations be analyzed for the curve
verification: 25, 40, 50, 200, and 400 pg/L.
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 Resources. Data were
reviewed for the Town of Walnut Cove (NPDES permit #NC0025526) for March, 2013. No transcription
errors except those noted in Finding D were detected.
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
Report reviewed by: Nick Jones
Date: February 13, 2014
Date: February 19, 2014