NC0081825_Inspection_20121009

AwA
NCDENR
DER FRO
OCT 1 5 2012
DW
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P. E. Dee Freeman
Governor Director Secretary
October 9,'2012
5242
Ms. Dianna McLaughlin
Town of Ansonville WVVTP
PO Box 437
Ansonville, NC 28007-
Dear Ms. McLaughlin:
Your letter received August 27, 2012, concerning corrective actions taken in response to the items
cited in the July 11, 2012 inspection report has been received and reviewed. The actions taken are
acceptable with thefollowing exceptions and comments:
Proficiency Testing
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.
Laboratory Response:
The proficiency testing samples are not run in conjunction with the field parameters on any
specific date. They are, however, run per the instructions included for each parameter limited to
pH and Ultra Low Residual Chlorine. The results speak for themselves. Our accuracy is
reflected in the acceptable results recognized by our vendor ERA. We routinely order a known
standard to assure field calibration of our instruments.
Auditors Response:
Some proficiency testing providers offer matrix -matched quality control samples to
accompany their PT samples. Please be aware that the use of these for proficiency testing is
unacceptable. Routine samples are not accompanied by matrix -matched samples.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet: www.ncwaterauality.orq
An Equal Opportunity \ Affirmative Action Employer
NorthCarolina
Naturally

Addressee #5242 Town of•Ansonville WWTP
Date: October 9, 2012
Page 2 of 4
Normal qc samples are acceptable, i.e. known pH buffers but not vendor supplied matrix
matched samples usually supplied along with the PT sample.
Please respond indicating that you are not analyzing known value PT samples,
supplied by the PT vendor, alongside your blind Pt samples.
E. Finding: The process control data is not documented as such 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 unitsof measure for all analyses. Ref: 15A NCAC 211 .0805
(g) (1)
Comment: Process control data was sometimes documented along with compliance data,
making it difficult to discem between the two types of data.
Laboratory Response:
We do not include process control data on the field laboratory bench sheets. Mr. Buddy
Waddell is our ORC • and he is charged with maintaining process control records.. We will
continue to include our settleable solids results as a ready reference for our routine review.
Settleable solids are not on a NPDES permit requirement.
Auditor Response:
It was- observed, by the auditor during the inspection that process control data was
sometimes documented along with compliance data, making it difficult to discern, between
the two types of data. It is required .that thelaboratoryclearly label, process control data as
such, wherever it is recorded. Clearly labeling the sample site, for example, "aeration basin'
will document that the data is -for process control and not compliance monitoring.
Please respond indicating that all process control data, that is any samples collected
from sample locations other than those specified in your NPDES permit, are labeled
as "process control" samples or labeled as to the sample location, for example
"`aeration basin".
Dissolved Oxygen — Standard Methods, 18"' Edition, 4500 0 G
F. Finding: The laboratory is not documenting the air calibration. -
Requirement: The meter must be calibrated prior to analysis of samples. The meter.inust be
calibrated either by the air calibration method or according to the manufacturer's calibration
procedure. The laboratory must document each time thata calibration is performed. Ref:
Technical Assistance for the Field Analysis of Dissolved Oxygen. (DO).
Laboratory Response:
Dissolved oxygen is not a NPDES permit .requirement on . our . permit #NC0081825.
Therefore, we do not feel compelled to submit results for compliance. Historically, we have
recorded our process observations on our monthly,DMR's for our record only.

Addressee #5242 Town of Ansonville WWTP
Date: October 9, 2012
Page 3 of 4
G. , Finding: The laboratory is not documenting the calibration time.
Requirement: The following criteria must be documented whenever sample analysis is
performed: Meter calibration and time(s) of calibration. Ref: Technical Assistance for the
Field Analysis of Dissolved Oxygen (DO).
Laboratory Response:
This is not a NPDES requirement. We observe the manufactures suggested calibration
protocol, for our process purposes.
(F and G .) Auditor Response:
We would like to clarify this issue. 15A-NCA-C 2B .0506 (b) (3) (J). states: The results of all
tests on the characteristics of the effluent, including' but not limited to NPDES permit
monitoring requirements, shall be reported on the monthly report forms.
This means, if you continue to analyze for DO at the effluent you must report that data on the
DMR. If that is the case you also are required to document the calibration of the meter and
the time the calibration is performed. If you choose to sample at another site other than the
final effluent, to monitor DO for plant operation purposes, ,than you would not be required to
report the data and also would not be required to document the calibration and calibration
time.
Please respond as to whether you are going to continue to analyze DO at the final
effluent site, report the data, document the calibration of the meter, and the calibration
time:
or
Please respond that you. will discontinue analyzing for DO at the final effluent
sampling site..
Total Residual Chlorine — Standard Methods, 18th Edition, 4500 CI G
We have received your five point calibration verification and it is acceptable. We would like to
make -the following recommendation for the next time you verify the calibration curve.
Recommendation: It is recommended that the laboratory verify the internal calibration using
the concentrations: 20, 35, 50, 200 and 400 Ng/L. (versus the 20, 50, 100, 250, and 400
pg/L concentrations you analyzed) This will verify the analytical range used to measure
Proficiency Testing (PT) and environmental samples, demonstrate accuracy at or below the
permit limit and allow the use of the 0.200 mg/L (Le., 200 pg/L) Gel Standard as the midrange
daily check standard. What we want to see is three standards between 50 NgIL and the
reporting level since 50 pg/L is the compliance limit and what we are really concerned with is
between the 50 and the reporting level standards.
- Standard Methods, 18th Edition, 4500.H+ B
L. Finding: The laboratory is not analyzing a check buffer on each analysis day.

Addressee #5242 Town of Ansonville WWTP
Date: October 9, 2012
Page4of4 •
Requirement: The meter must be calibrated with it least two buffers. In addition to the
calibration standards, the meter must be verified with a third calibration standard. The
calibration and check standard buffer must bracket the range of the samples being -analyzed.
The check standard buffer must read within= a range of ± 0.1 pH units to be acceptable. Ref:
Technical Assistance for Field Analysis of pH. -
Laboratory Response: .
Auditor Response:
Laboratory did not address this finding. Please respond that after the meter is
calibrated (currently with 3 buffers), one of the pH buffers (usually the 7.0 s.u. buffer) -
will 'be. analyzed as a quality control check prior to analyzing samples.
M. Finding: Values were reported that exceed the method specified accuracy (i.e., 0.1 units)
for this analysis.,
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).
Laboratory Response:
L. & M. It is our understanding that for NPDES compliance reporting on the electronic DMR's
that the cell is formatted for one place right of the decimal. Our field meter does record two
decimal places. Please advise as to what value should be:reported.
Auditor Response:
Please respond that all pH data on the DMR will be reported to one decimal
place.
We request that a written reply to these' items be provided within fifteen day of your receipt of this
letter. Thank you for your time and cooperation. If youhave questions, we can be contacted at (919)
733-3908.
Sincerely,
Jeffrey R. Adams -
Laboratory Section
Cc:. Dana Satterwhite
Fayetteville Regional Office