#5517_2020_0130_AO_FINAL

To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5517
Laboratory Name:
Town of Beaufort WTP
Inspection Type:
Field Municipal Maintenance
Inspector Name(s):
Anna Ostendorff
Inspection Date:
January 30, 2020
Date Forwarded for Initial
February 27, 2020
Review:
Initial Review by:
Michael Cumbus
Date Initial Review
February 28, 2020
Completed:
❑ Insp. Initial
® Insp. Reg
Cover Letter to use:
❑Insp. No Finding
❑Corrected
❑Insp. CP
❑Insp. Reg. Delay
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(to use: rt click, properties, check)
Unit Supervisor/Chemist III:
Beth Swanson
Date Received:
2/28/2020
Date Forwarded to Admin.:
3/2/2020
Date Mailed:
U
Special Mailing Instructions:

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL smi' -6
Director
5517
Mr. Wade Keeler
Town of Beaufort WTP
P.O. Box 390
Beaufort, NC 28516
NORTH CAROLINA
Environmental Quality
March 3, 2020
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW
LC) Maintenance Inspection
Dear Mr. Keeler:
Enclosed is a report for the inspection performed on January 30, 2020 by Anna Ostendorff.
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. Please describe the steps taken to prevent recurrence 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.
A copy of the laboratory's Certified Parameter List at the time of the audit is attached. This list
will reflect any changes made during the audit. 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 me at [phone] Ext. 259.
Sincerely,
Beth Swanson
Technical Assistance & Compliance Specialist
Division of Water Resources
Attachment
cc: Dana Satterwhite
Anna Ostendorff
File #5517
North Carolina Department of Environmental Quality i Division of Water Resources
-E 4405 Reedy Creek Road i 1623 Mail Service Cuter Raleigh, North Carohna 27699 1623
noanrcnnouNn
Mpatt hoior W 000,"rdnoway 919733.3908

LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION
AUDITOR(S):
LOCAL PERSON(S) CONTACTED
I. INTRODUCTION:
Town of Beaufort WTP
NC0072702 and NC0072699
910 Pine Street
Beaufort, NC 28516
5517
January 30, 2020
Field Municipal Maintenance
Anna Ostendorff
Wade Keeler
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 Town of Beaufort operates two water treatment plants with NPDES permits (Glenda Drive
WTP NPDES # NC0072702 and Pine Street WTP NPDES # NC0072699). The Field Laboratory
certification is used to analyze and report compliance data for both facilities. The Glenda Drive
and Pine Street WTPs began discharging into the Town of Beaufort sewer system effective
February and December -2019,--respectively. The facility expressed they would like -to-maintain
laboratory certification voluntarily.
All required Proficiency Testing (PT) Samples for the 2020 Calendar Year have not yet been
analyzed. The laboratory is reminded that results must be received by this office directly from the
vendor by September 30, 2020.
Contracted analyses are performed by Environmental Chemists (Certification # 94).
Approved Procedure documents for the analysis of the facility's currently certified Field
Parameters were provided at the time of the inspection.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation

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#5517 Town of Beaufort WTP
A. Finding: Error corrections are not always properly performed.
Requirement: All documentation errors shall 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; instead the correction shall be written
adjacent to the error. The correction shall be initialed by the responsible individual and the
date of change documented. Ref: 15A NCAC 02H .0805 (g) (1).
E. Finding: Chemical containers are not consistently dated when received and when
opened.
Requirement: Chemical containers shall be dated when received and when opened. Ref:
15A NCAC 02H .0805 (g) (7).
Comment: The analyst stated that containers are usually dated when received and when
opened. The current pH buffer containers did not have the date received or opened
documented.
C. Finding: The laboratory benchsheets for pH and Total Residual Chlorine are lacking
required documentation: the method or Standard Operating Procedure and the instrument
identification.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses and shall consist of: the method or
Standard Operating Procedure; instrument identification. Each item shall be recorded
each time samples are analyzed. Analyses shall conform to methodologies found in
Subparagraph (a)(1) of this Rule. Ref: 15 NCAC 02H .0805 (g) (2) (A) and (C).
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Method Reference; Instrument identification (serial number
preferred). Ref: NC WW/GW LC Approved Procedure for the Analysis of pH; INC WW/GW
LC Approved Procedure for the Analysis of Total Residual Chlorine (DPD Colorimetric by
SM 4500 Cl G-2011).
D. Finding: The laboratory benchsheet and calibration log for pH are lacking required
documentation: Units of measure.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses and shall consist of: the proper units
of measure. Each item shall be recorded each time samples are analyzed. Analyses shall
conform to methodologies found in Subparagraph (a)(1) of this Rule. Ref: 15 NCAC 02H
.0805 (g) (2) (L).
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Units of measure. Ref: NC WW/GW LC Approved Procedure for
the Analysis of pH.
E. Finding: The pH calibration log does not clearly label which buffers are used for
calibration and which are used to verify the calibration.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses and shall consist of: sample

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#5517 Town of Beaufort WTP
identification. Each item shall be recorded each time samples are analyzed. Analyses shall
conform to methodologies found in Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H
.0805 (g) (2) (1).
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: True values of buffers used for calibration; True value for the check
standard buffer. Ref: NC WW/GW LC Approved Procedure for the Analysis of pH.
Comment: The laboratory is calibrating the pH meter with 4.0, 7.0 and 10.0 S.U. buffers
and verifying the calibration with the 7.0 S.U. buffer.
F. Finding: The laboratory benchsheet for Total Residual Chlorine is lacking required
documentation: Daily Check Standard analysis time.
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Daily Check Standard analysis date and time(s). Ref: NC WW/GW
LC Approved Procedure for the Analysis of Total Residual Chlorine (DPD Colorimetric by
SM 4500 Cl G-2011).
Proficiency Testing
G. Finding: The laboratory is not documenting the preparation of PT Samples.
Requirement: PT Samples received as ampules are diluted according to the Accredited
PT Sample Provider's instructions. It is important to remember to document the
preparation of PT Samples in a traceable log or other traceable format. The diluted PT
Sample then becomes a routine Compliance Sample and is added to a routine sample
batch for analysis. No documentation is needed for whole volume PT Samples which
require no preparation, however the instructions must be maintained. Ref: Proficiency
Testing Requirements, February 19, 2020, Revision 5, Section 3.6.
Comment: Dating and initialing the instruction sheet for each prepared PT Sample would
satisfy the documentation requirement.
H. Finding: The laboratory is not documenting PT Sample analyses in the same manner as
routine Compliance Samples.
Requirement: All PT Sample analyses must be recorded in the daily analysis records as
-- - for any Compliance Sample. This -serves- as the permanent laboratory record. Ref:
Proficiency Testing Requirements, February 19, 2020, Revision 5, Section 3.6.
Requirement: The laboratory shall retain all records necessary to facilitate historical
reconstruction of the analysis and reporting of analytical results for PT Samples. This
means the laboratory must have available and retain for five years [pursuant to 15A NCAC
2H .0805 (a) (7) (E and (g) (1))] all of the raw data, including benchsheets, instrument
printouts and calibration data, for all PT Sample analyses and the associated QC analyses
conducted by all parameter methods. Ref: Proficiency Testing Requirements, February 19,
2020, Revision 5, Section 4.0.
Total Residual Chlorine — Standard Methods, 4500 CI G-2011 (Aqueous)
Finding: The laboratory is not verifying the instrument's Factory -set Calibration Curve
every 12 months.

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#5517 Town of Beaufort WTP
Requirement: Annual Factory -set Calibration Curve Verification: This type of calibration
curve verification must be performed initially, at least every 12 months and any time the
instrument optics are serviced. Zero the instrument with a Calibration Blank and then
analyze a Method Blank and a series of five standards (do not use gel or sealed liquid
standards for this purpose). The calibration standard values obtained must not vary by
more than ±10% from the known value for standard concentrations greater than or equal
to 50 pg/L and must not vary by more than ±25% from the known value for standard
concentrations less than 50 fag/L. Ref: NC WW/GW LC Approved Procedure for the
Analysis of Total Residual Chlorine (DPD Colorimetric by SM 4500 Cl G-2011).
Comment: The Factory -set Calibration Curve was last verified on February 12, 2018.
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 Glenda Drive WTP (NPDES
permit # N00072702) for April 2018, November 2018 and February 2019. No transcription
errors were observed. The facility appears to be doing a good job of accurately transcribing
data.
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Correcting the above -cited Findings will help this laboratory to produce quality data and meet
Certification requirements. The inspector would like to thank the staff for their assistance during
the inspection and data review process. Please respond to all Findings and include
supporting documentation, implementation dates and steps taken to prevent recurrence
for each corrective action.
Report prepared by: Anna Ostendorff Date: February 27, 2020
Report reviewed by: Michael Cumbus Date: February 28, 2020

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