#5532_2020_0226_JMS_FINAL

Laboratory Cert. #:
5532
Laboratory Name:
Town of Maiden WWTP
Inspection Type:
Field Municipal Maintenance
Inspector Name(s):
Jason Smith
Inspection Date:
February 26, 2020
Date Forwarded for Initial
March 11, 2020
Review:
Initial Review by:
Tom Halvosa
Date Initial Review
March 13, 2020
Completed:
❑ Insp. Initial
® Insp. Reg
Cover Letter to use:
❑Insp. No Finding
❑Corrected
❑Insp. CP
❑Insp. Reg. Delay
(to use: rt click, properties, check)
Unit Supervisor/Chemist II:
Todd Crawford
Date Received:
March 17, 2020
Date Forwarded to Admin.:
March 18, 2020
Date Mailed;
Special Mailing Instructions:

ROY COOPED.
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
H
Director
5532
Mr. Tim Hedrick
Town of Maiden WWTP
19 North Main Avenue
Maiden, NC 28650
NORTH CAROLINA
Environmental Quality
March 19, 2020
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW
LC) Maintenance Inspection
Dear Mr. Hedrick:
Enclosed is a report for the inspection performed on February 26, 2020 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.
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,
z 5 17: -0 -e� -, �
Todd Crawford
Technical Assistance & Compliance Specialist
Division of Water Resources
Attachment
cc: Jason Smith, Dana Satterwhite
North Carolina Department of Environmental Quality I Division of Water Resources
D-EQ5 4405 Reedy Creek Road 1 1623 Mail Service Center ¢ Raleigh, North Carolina 27699-1623
NORM CAROL
a� uC4 ESILw r 919.733.3908

LABORATORY NAME:
NPDES PERMIT :
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
I. INTRODUCTION:
Town of Maiden WWTP
NC0039594
2090 W Finger Extension
Maiden, NC 28650
5532
February 26, 2020
Field Municipal Maintenance
Jason Smith
Tim Hedrick and Chris Bagshaw
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 02H .0800 for the analysis of environmental samples.
II. GENERAL COMMENTS:
The facility is neat and well organized and has all the equipment necessary to perform the
analyses. Records are well organized and easy to retrieve.
All required Proficiency Testing (PT) Samples for the 2020 PT 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.
The laboratory is reminded that Standard Operating Procedure (SOP) documents are required to
be implemented by July 1, 2020. Additionally, a documented training program for current and
future analysts must be implemented by August 1, 2020. These requirements and the SOP
templates posted on the NC WW/GW LC website were discussed during the inspection. Any time
changes are made to laboratory procedures, the laboratory must update the SOP document(s)
and inform relevant staff. In some instances, the laboratory may need to create an SOP to
document how new functions or policies will be implemented.
The laboratory is also reminded that SOPs are intended to describe procedures exactly as they
are to be performed. Use of the word "should" is not appropriate when describing requirements
(e.g., Quality Control (QC) frequency, acceptance criteria, etc.). Evaluate all SOPs for the proper
use of the word "should".

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#5532 Town of Maiden WWTP
Contracted analyses are performed by Water Tech Labs, Inc. (Certification # 50).
R 0 01 & � �U i ti
Documentation
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).
Comment: Some instances of overwriting and multiple lines through errors were
observed.
D. Finding: The laboratory benchsheet is lacking required documentation: the method or
Standard Operating Procedure.
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. 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 021-1.0805 (g) (2) (A).
Comment: The methods referenced on the benchsheets do not include the approval year.
A copy of the Certified Parameter List (CPL) is included with this report that lists the
methods as they are to be documented on the benchsheet.
C. Finding: The laboratory benchsheet is lacking required documentation: 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 instrument
identification. Each item shall be recorded each time samples are analyzed. Ref: 15A
NCAC 02H .0805 (g) (2) (C).
Comment: This Finding applies to Total Residual Chlorine (TRC), Dissolved Oxygen
(DO), pH and Temperature. The meter model was identified for Conductivity.
Recommendation: It is recommended that the instruments be identified by model and
serial number.
D. Finding: The laboratory benchsheet is lacking required documentation: the proper 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

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#5532 Town of Maiden WWTP
of measure. Each item shall be recorded each time samples are analyzed. Ref: 15A
NCAC 02H .0805 (g) (2) (L).
Comment: The units of measure were missing from the Dissolved Oxygen (DO),
Conductivity and pH benchsheets and from the DO calibration log.
E. Finding: The laboratory benchsheet is lacking required documentation: facility name and
permit number.
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Facility name, sample site (ID or location), and permit number. Ref:
NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen (DO), NC
WW/GW LC Approved Procedure for the Analysis of pH, NC WW/GW LC Approved
Procedure for the Analysis of Specific Conductance (Conductivity), NC WW/GW LC
Approved Procedure for the Analysis of Temperature and NC WW/GW LC Approved
Procedure for the Analysis of Total Residual Chlorine (DPD Colorimetric by SM 4500 Cl G-
2011).
F. Finding: The sample collector/analyst is not clearly identified on the benchsheet.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses and shall consist of: the sample
collector; the signature or initials of the analyst. Each item shall be recorded each time
samples are analyzed. Ref: 15A NCAC 02H .0805 (g) (2) (D) and (E).
Comment: This Finding applies to all parameters. The benchsheet needs to make it clear
that the "Tech" is the person that collected and analyzed the sample.
G. Finding: Values for pH were reported that exceed the method specified accuracy of 0.1
units.
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-2011. (6).
Comment: This Finding applies to reporting pH values on the Discharge monitoring
Report (DMR).
Recommendation: It is recommended that PT Sample results continue to be reported
to two decimal places.
H. Finding: The true value of the gel -type standard on the TRC benchsheet is not correct.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses and shall consist of: the quality
control assessments. Each item shall be recorded each time samples are analyzed. Ref:
15A NCAC 02H .0805 (g) (2) (0).
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: True value of the Daily Check Standard(s). Ref: NC WW/GW LC

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#5532 Town of Maiden WWTP
Approved Procedure for the Analysis of Total Residual Chlorine (DPD Colorimetric by SM
4500 Cl G-2011).
Comment: The value printed on the benchsheet was not updated the last time a new true
value was assigned. The value from the previous year was on the benchsheet but marked
out.
Proficiency Testing
Finding: Additional QC beyond what is routine for Compliance Samples is being analyzed
with PT Samples.
Requirement: Laboratories are required to analyze an appropriate PT Sample by each
parameter method on the laboratory's CPL. The same PT Sample may be analyzed by
one or more methods. Laboratories shall conduct the analyses in accordance with their
routine testing, calibration and reporting procedures, unless otherwise specified in the
instructions supplied by the Accredited PT Sample Provider. This means that they are to
be logged in and analyzed using the same staff, sample tracking systems, standard
operating procedures including the same equipment, reagents, calibration techniques,
analytical methods, preparatory techniques (e.g., digestions, distillations and extractions)
and the same quality control acceptance criteria. PT Samples shall not be analyzed with
additional quality control. They are not to be replicated beyond what is routine for
Compliance Sample analysis. Although, it may be routine to spike Compliance Samples, it
is neither required, nor recommended, for PT Samples. PT sample results from multiple
analyses (when this is the routine procedure) must be calculated in the same manner as
routine Compliance Samples. Ref: Proficiency Testing Requirements, February 19, 2020,
Revision 5, Section 3.6.
Comment: The laboratory analyzes an additional known QC standard from the PT vendor
with PT Samples.
Comment: Standards that are provided with the true values in a sealed envelope, are not
considered PT Samples and do not meet the PT requirements outlined in 15A NCAC 02H
.0800. Laboratories must not analyze additional standards with known concentrations
along with PT Samples with unknown concentrations, as this is not the routine testing
protocol for Compliance Samples. This is not to say that they cannot be used for
troubleshooting purposes before analyzing a remedial PT Sample. This would be
considered part of the corrective action plan.
J. Finding: PT Samples are not being analyzed in the same manner as routine Compliance
Samples.
Requirement: Laboratories are required to analyze an appropriate PT Sample by each
parameter method on the laboratory's CPL. The same PT Sample may be analyzed by
one or more methods. Laboratories shall conduct the analyses in accordance with their
routine testing, calibration and reporting procedures, unless otherwise specified in the
instructions supplied by the Accredited PT Sample Provider. This means that they are to
be logged in and analyzed using the same staff, sample tracking systems, standard
operating procedures including the same equipment, reagents, calibration techniques,
analytical methods, preparatory techniques (e.g., digestions, distillations and extractions)
and the same quality control acceptance criteria. PT Samples shall not be analyzed with
additional quality control. They are not to be replicated beyond what is routine for
Compliance Sample analysis. Although, it may be routine to spike Compliance Samples, it

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#5532 Town of Maiden WWTP
is neither required, nor recommended, for PT Samples. PT sample results from multiple
analyses (when this is the routine procedure) must be calculated in the same manner as
routine Compliance Samples, Ref: Proficiency Testing Requirements, February 19, 2020,
Revision 5, Section 3.6.
Comment: The laboratory is analyzing pH and TRC PT Samples multiple times and
averaging the results for reporting. NC WW/GW LC does not require replicate or duplicate
analyses for Field parameters and the laboratory does not duplicate routine Compliance
Samples. If multiple replicates are analyzed for pH, the values cannot be averaged due to
the logarithmic nature of pH concentration. All values must be reported.
K. 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 (i.e.,
TRC) would satisfy the documentation requirement.
Conductivity —Standard Methods, 2510 5-2011 (Aqueous)
L. Finding: The laboratory is not analyzing a second -source calibration verification check
standard.
Requirement: Analyze and document a second -source calibration verification check
standard prior to compliance sample analysis. It is recommended that this standard value
approximate (may be higher or lower than the calibration standard, as applicable) the
expected range of sample values measured. The value obtained for the calibration
verification check -standard must read within 10% of the true value of the calibration
verification 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
Specific Conductance (Conductivity).
Comment: Please note that Conductivity standards may not be diluted.
M. Finding: The laboratory is not performing a Post -Analysis Calibration Verification when
performing multiple sample analyses.
Requirement: When performing multiple sample analyses, a post -analysis calibration
verification must be analyzed at the end of the run. It is recommended that a mid -day or a
mid -batch calibration verification be performed when samples are analyzed over an
extended period of time. The value obtained for the post -analysis calibration verification
check -standard must read within 10% of the standard's true value. If the obtained value is
outside of the ±10% range, corrective action must be taken. If recalibration is necessary,
all samples analyzed since the last acceptable calibration verification must be reanalyzed,
if possible. If samples cannot be reanalyzed, the data must be qualified. Ref: NC WW/GW
LC Approved Procedure for the Analysis of Specific Conductance (Conductivity).

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#5532 Town of Maiden WWTP
Comment: This is applicable when the laboratory analyzes stream samples.
N. Finding: The probe is not rinsed with sample prior to analysis.
Requirement: Thoroughly rinse conductivity cell with one or more portions of sample prior
to sample measurement. Ref: NC WW/GW LC Approved Procedure for the Analysis of
Specific Conductance (Conductivity).
O. Finding: The Automatic Temperature Compensator (ATC) check is not being properly
performed.
Requirement: The ATC must be verified prior to initial use and annually (i.e., 12 months)
thereafter at two temperatures by analyzing a standard or sample at 25°C (i.e., the
temperature to which conductivity values are reported) and a temperature(s) that brackets
the temperature ranges of the environmental samples routinely analyzed. This may require
the analysis of a third temperature reading that is > 250C (see #3 below). The manner in
which the ATC is verified may depend upon the meter's capabilities and the
manufacturer's instructions. The following is one option:
1. Pour an adequate amount of conductivity standard or sample into a beaker or other
container and analyze at 25°C. Document the temperature and conductivity value.
2. Lower the temperature of the standard or sample (e.g., by placing the container in a
refrigerator or ice chest) to less than the lowest anticipated sample temperature and
analyze. Document the temperature and conductivity value.
3. If samples greater than 25°C are to be analyzed, perform the following additional step:
Raise the temperature above 250C to greater than the highest anticipated sample
temperature (e.g., by placing the container in a hot water bath) and analyze. Document
the temperature and conductivity value.
As the temperature increases or decreases, the value of the conductivity standard or
sample must be within ±10% of the true value of the standard or ±10% of the value of the
sample at 25°C. If not, corrective action must be taken. Ref: NC WW/GW LC Approved
Procedure for the Analysis of Specific Conductance (Conductivity).
Comment: The most recent verification was performed at 8.2 °C, 20.8 °C and 31.1 'C.
Data reviewed included stream samples that were below 8.2 'C.
Dissolved Oxygen — Standard Methods, 4500 O G-2011 (Aqueous)
P. Finding: The laboratory is not calibrating the meter at each sample site prior to analysis or
performing a Post -Analysis Calibration Verification when analyses are performed at
multiple sample sites.
Requirement: When performing analyses at multiple sample sites, the meter must be
calibrated at each sample site prior to analysis or a post -analysis calibration verification
must be performed at the end of the run, regardless of meter type. The calculated
theoretical DO value must verify the meter reading within ±0.5 mg/L. If the meter
verification does not read within ±0.5 mg/L of the theoretical DO, corrective action must be
taken. If the meter is not calibrated at each sample site, it is recommended that a mid -day
calibration be performed when samples are extended over an extended period of time.
Ref: NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen (DO).
Comment: This is applicable when the laboratory analyzes stream samples.

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#5532 Town of Maiden WWTP
Q. Finding: The annual temperature -measuring device check procedure is not performed
correctly.
Requirement: All compliance temperature -measuring devices without a valid NIST
certificate must be checked initially and every 12 months against an NIST traceable
temperature -measuring device and the process documented. To check a compliance
temperature -measuring device, compare readings at two temperatures that bracket the
range of compliance samples routinely analyzed against an NIST traceable temperature -
measuring device and record all four readings. The readings from both devices must
agree within 0.5°C. If they do not, the device may not be used for temperature compliance
monitoring. Ref: NC WW/GW LC Approved Procedure for the Analysis of Temperature.
Please submit properly performed temperature®measuring device verification(s)
with the response to this report.
Comment: The laboratory has their contract lab check their NIST thermometer, and then
they use it to verify the other thermometers and meters used by the laboratory.
Thermometers must be verified directly with an NIST traceable temperature -measuring
device that has current NIST traceability.
Comment: The comparisons were performed at only one temperature.
Comment: If a compliance temperature -measuring device with its own valid NIST
traceable certificate is used to measure reported temperatures, initial verification against
another NIST traceable temperature -measuring device is not required. The device may be
used beyond its stated expiration date provided it is verified prior to its next use and at
least every 12 months thereafter against another NIST traceable temperature -measuring
device.
R. Finding: Temperature sensor check readings for devices used for compliance monitoring
varied more than 0.5°C from the NIST traceable thermometer reading.
Requirement: To check a compliance temperature -measuring device, compare readings
at two temperatures that bracket the range of compliance samples routinely analyzed
against an NIST traceable temperature -measuring device and record all four readings.
The readings from both devices must agree within 0.5°C. If they do not, the device maV
not be used for temperature compliance monitoring. Ref: NC WW/GW LC Approved
Procedure for the Analysis of Temperature.
Comment: This is applicable to the DO meter which varied by + 0.6 °C; however, this may
be influenced by the two-step verification process described in Finding P. The analyst
stated that use of the Conductivity meter would be implemented immediately for
measuring temperature of stream samples. The conductivity meter was within 0.5 °C of
the verified thermometer. However, as noted in Finding P, the Conductivity meter was not
properly verified against an NIST traceable thermometer, so switching meters does not
necessarily address this Finding.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) and contract lab reports to DMRs submitted to the North Carolina Division of Water

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#5532 Town of Maiden WWTP
Resources. Data were reviewed for the Town of Maiden WWTP (NPDES permit # NC0039594)
for April, July and September 2019. The following errors were noted:
Value on Renchsheet
Date
Parameter
Location
Value on DMR
*Contract Lab Data
7/1/19
Temperature
Effluent
22.3 °C
22.5 °C
9/3/19
Total Nitrogen
Effluent
*8.26 mg/L
3.5 mg/L
To avoid questions of legality, it is recommended that you contact the appropriate Regional
Office for guidance as to whether an amended DMR(s) will be required. A copy of this report
will be made available to the Regional Office.
Correcting the above -cited Findings and implementing the Recommendations 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: Jason Smith Date: March 11, 2020
Report reviewed by: Tom Halvosa Date: March 17, 2020

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