#5038 09 Final

INSPECTION REPORT ROUTING SHEET

To be attached to all inspection reports in-house only.

Laboratory Cert. #: 5038

Laboratory Name: Wastewater Management L.L.C.

Inspection Type: Field Maintenance

Inspector Name(s): Jeffrey R. Adams

Inspection Date: December 29, 2009

Date Report Completed: January 15, 2010

Date Forwarded to Reviewer: January 15, 2010

Reviewed by: Ramon L. Cook

Date Review Completed: January 20, 2010 __________________

Cover Letter to use: Insp. Initial X Insp. Reg. Insp. No Finding Insp. CP

Unit Supervisor: Dana Satterwhite

Date Received: January 20, 2010

Date Forwarded to Alberta: January 22, 2010

Date Mailed:

_____________________________________________________________________

On-Site Inspection Report

LABORATORY NAME: Wastewater Management, L.L.C.

NPDES PERMIT #: NC0023442, WQ0002927, WQ0020808, WQ0024461, WQ0021204,
NC0048429, WQ0019754, & WQ0013502

ADDRESS: 704 Sanford Rd
Pittsboro, NC 27312

CERTIFICATE #: 5038

DATE OF INSPECTION: December 29, 2009

TYPE OF INSPECTION: Field Maintenance

AUDITOR(S): Jeffrey R. Adams

LOCAL PERSON(S) CONTACTED: Randall Jarrell

I. INTRODUCTION:

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:

The laboratory was neat. Records were well maintained and organized, however, some quality control
procedures need to be implemented.

The laboratory was given copies of the Technical Assistance Documents for all field parameters during the
inspection.

III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:

Total Residual Chlorine – Standard Methods, 18th Edition, 4500 Cl G

A. Finding: The laboratory is not using an instrument that will detect and measure Total Residual
Chlorine at concentrations that are below the permitted discharge requirement for all the facilities it
services.

Requirement: Each facility must have glassware, chemicals, supplies, equipment, and a source of
distilled or deionized water that will meet minimum criteria of the approved methodologies. Ref: 15
NCAC 02H .0805 (g) (4).

Requirement: In accordance with the directive from the Division of Water Quality, permittees must
utilize an instrument or method that will detect and measure Total Residual Chlorine (TRC)
concentrations to levels that are below the permit discharge requirements. The use of hand-held
meters, sometimes referred to as pocket colorimeters, is only permissible when a facility has no
effluent limit for TRC. Ref: Division of Water Quality letter dated August 14, 2001.

Comment: One of the waste facilities that the laboratory is monitoring has a Total Residual
Chlorine permit limit of 17 µg/L. The laboratory is using a Pocket Colorimeter™. These instruments
are generally reliable only at concentrations of 100 µg/L or greater.
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#5038 Wastewater Management, L.L.C.

IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing contract lab reports to Discharge Monitoring Reports (DMRs ) and
Non Discharge Wastewater Monitoring Reports (NDMRs) submitted to the North Carolina Division of Water
Quality. Data were reviewed for Cedar Village (NPDES permit #NC0048429), Domtar (Non Discharge
permit #WQ0002927), 3M Pittsboro (Non Discharge permit #WQ0020808), White Cross VFD (Non
Discharge permit #WQ0024461), North Chatham VFD (Non discharge permit #WQ0021204), Luck Stone
(Non Discharge permit #WQ0019754, and Towers (Non Discharge permit #WQ0013502) for September,
October and November, 2009. The following errors were noted:
For the Cedar Village facility, the permit compliance limit for Total Residual Chlorine (TRC) is
17 µg/L. The laboratory is reporting TRC values in mg/L on the DMRs yet the DMR header
lists the units of measure as µg/L (i.e., the 0.34 µg/L recorded should have been 0.34 mg/L
or 340 µg/L) for September and October, 2009. The problem was detected and corrected in
November, 2009.

In order to avoid questions of legality, it is recommended that you contact the appropriate Regional
Office for guidance as to whether amended Discharge Monitoring Reports will be required for the
months of September and October. A copy of this report will be forwarded to the Regional Office.

V. CONCLUSIONS:

Correcting the above-cited finding will help this lab to produce quality data and meet certification
requirements. The inspector would like to thank the staff for its assistance in the inspection and data review
process. Please respond to all findings.

Report prepared by: Jeffrey R. Adams Date: January 15, 2010
Report reviewed by: Ramon Cook Date: January 20, 2010