#5413_0306_finalTC_2015_

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North Carolina Department of Environment and Natural Resources
Pat McCrory Donald R. van der Vaart
Governor Secretary
March 26, 2015
Environmental Services
Charles John Scozzari Jr.
P.O. Box 1054
Jacksonville, NC 28541
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Scozzari:
Enclosed is a report for the inspection performed on March 6, 2015 by Todd Crawford. 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 and include
an implementation date for each corrective action. 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 (919)
733-3908.
Attachment
cc: Dana Satterwhite
Todd Crawford
Sincerely,
C_��
Dana Satterwhite, Environmental Program Supervisor
Division of Water Resources
Water Sciences Section
INC 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] t FAX [phone]
Internet: www.dwglab.oM
An Equal Opportunity iAtfirmative 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:
5413
Environmental Services
Field Maintenance
Todd Crawford
March 6 2015
March 23 2015
March 23 2015
Beth Swanson
March 23 2015
❑ Insp. Initial
❑ Insp. No Finding
❑ Corrected
® Insp. Reg.
❑ Insp. CID
❑ Insp. Reg. Delay
Dana Satterwhite
March 23 2015
March 26 2015
March 26 2015

LABORATORY NAME:
WATER QUALITY PERMIT # :
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
On -Site Inspection Report
Environmental Services
NCO071706
P.O. Box 1054
Jacksonville, NC 28541
5413
March 6, 2015
Field Maintenance
Todd Crawford
LOCAL PERSON(S) CONTACTED: Charles John Scozzari, Jr.
INTRODUCTION:
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.
Proficiency Testing (PT) samples for the 2015 proficiency testing calendar year have not yet been
analyzed. The laboratory is reminded that these results must be submitted to this office directly from the
vendor by September 30, 2015.
Contracted analyses are performed by Environmental Chemists, Inc. (Certification #94).
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.
The requirements associated with Findings A, B, and C have been implemented by our program since the
last inspection.
FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
Comment: The laboratory benchsheet was missing the instrument identification for all parameters. The
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 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. This requirement is a new policy that has been implemented by our program

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since the last inspection. Notification of acceptable corrective action (i.e., a statement that an updated
benchsheet, which was provided by the auditor and includes instrument identifications for all parameters,
would be put into use on 3/23/15) was received by email on 3/19/15. No further response is necessary
for this finding.
Performance Testing
A. 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.
Comment: Dating and initialing the instruction sheet for the preparation of the Total Residual
Chlorine PT would satisfy the documentation requirement.
B. 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 as additional quality control. 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.
C. 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 analysis of PT samples is designed to evaluate the entire process used to
routinely report environmental analytical results; therefore, PT samples must be analyzed and the
process documented in the same manner as environmental samples.
Total Residual Chlorine — Standard Methods, 4500 CI G-2000
Comment: The laboratory was not verifying the instrument's factory set curve every 12 months. The
Approved Procedure for the Analysis of Total Residual Chlorine document states: 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 than or equal to 50 µg/L and must
not vary by more than 25% of the known value for standard concentrations less than 50 µg/L. The overall
correlation coefficient of the curve must be >_0.995. Demonstration of acceptable corrective action (i.e.,

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documentation of a passing curve verification) was received by email on 3/18/15. No further response is
necessary for this finding.
Comment: The laboratory was not verifying the Gel® Standard every 12 months. The Approved
Procedure for the Analysis of Total Residual Chlorine document states: 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 µg/L
standard would be verified. Demonstration of acceptable corrective action (i.e., documentation of gel
standard verification) was received by email on 3/18/15. No further response is necessary for this
finding.
Comment: The units of measure listed in the calibration check standard column were "mg/L", while the
value documented was %tg/L". 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, sample site, sample collector, and sample analysis time. The field bench
sheets must provide a space for the signature of the analyst, and proper units of measure for all
analyses. Notification of acceptable corrective action (i.e., a statement that an updated benchsheet, which
was provided by the auditor and includes proper units of measure for all parameters, would be put into
use on 3/23/15) was received by email on 3/19/15, No further response is necessary for this finding.
PH — Standard Methods, 4500 H+113-2000
Total Residual Chlorine — Standard Methods, 4500 CI G-2000
Comment: The units of measure for pH and Total Residual Chlorine samples were not documented on
the benchsheets. 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, sample 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. Notification
of acceptable corrective action (i.e., a statement that an updated benchsheet, which was provided by the
auditor and includes proper units of measure for all parameters, would be put into use on 3/23/15) was
received by email on 3/19/15. No further response is necessary for this finding.
PH — Standard Methods, 4500 H+B-2000
Comment: Although the analyst stated that he was checking the calibration with a pH 7.0 buffer, he was
not documenting the result. This is considered pertinent information. The North Carolina Administrative
Code, 15A NCAC 2H .0805 (g) (2) states: A record of instrument calibration where applicable, must be
filed in an orderly manner so as to be readily available for inspection upon request. The Approved
Procedure for the Analysis of pH document states: For routine work, use a pH meter accurate and
reproducible to 0.1 pH unit with a range of 0 to 14, equipped with a temperature compensation device.
Follow all manufacturers' recommendations for the calibration of the meter each analysis day. In all
cases, the meter must be calibrated with at least two buffers. Calibrating with the pH 4 and pH 10 buffers
meets standard methods requirements and brackets the pH range for most monitoring (with the exception
of sludge) scenarios. The calibration; however, must bracket the range of the samples being analyzed. In
addition to the calibration standards, the meter must be verified with a third calibration standard (e.g., pH
7 buffer). In order to meet the above -specified criteria the standard must read within a range of pH 6.9 to
7.1 to be acceptable. Notification of acceptable corrective action (i.e., a statement that an updated
benchsheet, which was provided by the auditor and includes space for the documentation of the analysis
time and obtained pH value of the check buffer, would be put into use on 3/23/15) was received by email
on 3/19/15. No further response is necessary for this finding.

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Dissolved Oxygen — Standard Methods, 4500-0 G-2001
Comment: The time that the meter is calibrated is not being documented. This is considered pertinent
information. The North Carolina Administrative Code, 15A NCAC 2H .0805 (g) (2) states: A record of
instrument calibration where applicable, must be filed in an orderly manner so as to be readily available
for inspection upon request. Notification of acceptable corrective action (i.e., a statement that an updated
benchsheet, which was provided by the auditor and includes space for the documentation of the
calibration time, would be put into use on 3/23/15) was received by email on 3/19/15. No further
response is necessary for this finding.
D. Finding: The meter is not being calibrated according the manufacturer's instructions.
Requirement: Ensure that the sponge inside the instrument's calibration chamber is moist. Insert
the probe into the calibration chamber. Ref: YSI 550A Operator's Manual.
Comment: The calibration well was missing. The calibration was being performed with the probe
inserted into a small plastic bottle with a damp sponge in the bottom. The bottle neck is small
enough that it fits snuggly around the probe housing. However, the bottle is not deep enough to
insert the probe past the side vents on the probe casing. This means the probe is exposed to
atmospheric air during the calibration process. The probe must be in saturated air to achieve a
proper calibration. The accuracy of DO readings are dependent upon a proper meter calibration.
Recommendation: It is recommended that a replacement calibration well be obtained from the
manufacturer.
Comment: If a proper calibration well cannot be obtained. An acceptable alternative would be to
place a damp sponge inside a plastic baggie and seal the baggie around the probe, with a rubber
band, during the calibration procedure. Care should be taken to insure that the air inside the
baggie has had time to become saturated and stable before beginning the calibration.
Temperature — Standard Methods, 2550 B-2000
E. Finding: The temperature correction factor is not being applied to the reported temperature
values.
Requirement: All thermometers and temperature measuring devices must be checked every 12
months against a National Institute of Standards and Technology (NIST) traceable thermometer.
The process must be documented and proper corrections made to all compliance data. Ref: NC
WW/GW LC Approved Procedure for the Analysis of Temperature.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks, etc.) and
contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of
Water Resources. Data were reviewed for November and December, 2014, and January, 2015. No
transcription errors were detected, however, values with a "less than" sign were reported in the "average"
field on the DMR. The NC DWR NPDES Permitting Calculation of Data document states: Complications
may arise in calculations when dealing with testing results showing values of less than a minimum
detection level for the testing method. Current Division policy gives permittees the benefit of doubt all the
way to the lowest levels when performing calculations using such "less than" values. When calculating an
arithmetic mean, you may consider a "less than" value as equal to zero For the calculation of a geometric
mean, a "less than" value may be considered to be equal to one Remember, this procedure pertains only
to the calculation of an average You must report individual data values on the DMR exactly as reported

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to you by your laboratory. The NC DWR NPDES Permitting Instructions for Completing a DMR states:
Values of results which are less than a detectable limit should be reported in the daily cells using the "less
than" symbol M 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.
V. CONCLUSIONS:
Correcting the above -cited findings and implementing the recommendation 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 and include
an implementation date for each corrective action.
Report prepared by: Todd Crawford Date: March 23, 2015
Report reviewed by: Beth Swanson Date: March 23, 2015