#5242_2019_0305_TS_FINAL

Laboratory Cert. #:
5242
Laboratory Name:
Town of Ansonville WVVfP
Inspection Type:
Field Municipal Maintenance
Inspector Name(s):
Tonja Springer, Todd Crawford and Beth Swanson
Inspection Date:
March 5, 2019
Date Forwarded for Initial
Review:
March 14, 2019
Initial Review by:
Todd Crawford and Beth Swanson
Date Initial Review
Completed:
March 22, 2019
Cover Letter to use:
❑ Insp. Initial ❑ Insp. Reg
❑Insp. No Finding ®Insp. CP
❑Corrected ❑Insp. Reg. Delay
Unit Supervisor/Chemist II:
Todd Crawford
Date Received:
March 14, 2019
Date Forwarded to Admin.:
March 29, 2019
Date Mailed:
April 10, 2019
Special Mailing Instructions:
Send copies to Jay Zimmerman, Cyndi Karoly, Trent Allen and Mark Brantley

MICHALL S, REGA
Ii.JN A CULPEPPE
April 10, 2019
5242
Ms. Dianna McLaughlin
Town of Ansonville WWTP
P.O. Box 437
Ansonville, NC 28007
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Ms. McLaughlin:
Enclosed is a report for the inspection performed on March 5, 2019 by Tonja Springer. We are
concerned with the Findings that were cited previously and not corrected. The number and severity of
the Findings; which have not been corrected even after the laboratory stated corrective actions had
been implemented, makes the validity of reported data suspect. Decertification for all parameters will
be recommended for the infractions listed below.
Laboratory Decertification Ref: 15A NCAC 2H .0807 (a) (1), (2), (10), (13) and (14):
A laboratory may be decertified for any or all parameters for up to one year for any or all of the following
infractions:
(1) Failing to maintain the facilities, or records, or personnel, or equipment, or quality control
program as set forth in the application, and these Rules; or
(2) Submitting inaccurate data or other information; or
(10) Failing to supply analytical data requested by the State Laboratory; or
(13) Failing to respond to requests for information by the date due; or
(14) Failing to comply with any other terms, conditions, or requirements of this Section or of a
Laboratory certification.
Civil Penalties Ref: 15A NCAC 02H .0807 (f):
Civil penalties may be assessed against a laboratory which violates or fails to act in accordance with
any of the terms, conditions, or requirements of the Rules in this Section or of a laboratory certification.
A laboratory is subject to both civil penalties and decertification.
North Carolina Department of Environmental Quality I Division of Water Resources
1623 Mail Service Center I Raleigh, North Carolina 27699-1623
Phone [phone]/Fax 919,733.6241

A copy of the laboratory's Certified Parameter List at the time of the audit is attached. This list
reflects the laboratory's scope of accreditation at the time of the audit. Copies of the checklists
completed during the inspection may be requested from this office. 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].
Sincerely,
Todd Crawford
Technical Assistance & Compliance Specialist
NC WW/GW Laboratory Certification Branch
Attachment
cc: Dana Satterwhite, Tonja Springer, Cyndi Karoly,
Trent Allen, Mark Brantley, Master File #5242

- • Z 0
LABORATORY NAME: Town of Ansonville WWTP
NPDES PERMIT#: NCO081825
ADDRESS: 8778 US Hwy. 52 N
Ansonville, NC 28007
CERTIFICATE #: 5242
DATE OF INSPECTION: March 5, 2019
TYPE OF INSPECTION: Field Municipal Maintenance
AUDITOR(S): Tonja Springer, Todd Crawford and Beth Swanson
LOCAL PERSON(S) CONTACTED: Jason Mullins and Chris Mullins
This laboratory was inspected by representatives 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:
An unannounced inspection was conducted at the request of the Fayetteville Regional Office of
the NC Department of Environmental Quality (NCDEQ) Division of Water Resources (DWR) due to
concerns about the lack of laboratory records and supporting documentation. At the time of the
inspection Dianna McLaughlin, the designated supervisor, contact person and primary analyst, was
not present.
The lack of supporting documentation is a violation of 15A NCAC 02B .0506 (a)(1)(D) which
states: "In order to document information contained in reports submitted to the Director pursuant
to this Section, the owner of each pollution control facility is required to retain or have readily
available for inspection by the Division, the following items for a period of at least three years
from report submission: (i) the original laboratory reports from any certified laboratory utilized for
sample analysis. Such reports must be signed by the laboratory supervisor, and must indicate
the date and time of sample collection and analysis, and the analysts' name; (ii) bench notes
and data logs for sample analyses performed by the pollution control facility staff or operator in
responsible charge, whether or not the facility has a certified lab; and (iii) copies of all process
control testing" and 15A NCAC 2H .0805 (g) (1) which states: "Data pertinent to each analysis
must be maintained for five years".
All required Proficiency Testing (PT) Samples for the 2019 PT Calendar Year have not yet been
analyzed.
Contracted analyses are performed by Environment 1, Inc. (Certification #10).
Current Quality Assurance Policies for Field Laboratories and Approved Procedure documents
for the analysis of the facility's currently certified Field Parameters were provided at the time of
this inspection and the previous inspections on July 11, 2012 and November 27, 2017.

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#5242 Town of Ansonville WWTP
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
General Laboratory
A. Finding: The supervisor is not adequately ensuring that technical personnel are adhering
to analytical method and quality control requirements for reported compliance monitoring
data.
Requirement: The supervisor shall provide personal and direct supervision of the
technical personnel and be held responsible for the proper performance and reporting of all
analyses made for these rules. Ref: 15A NCAC 2H .0805 (a) (3) (c).
Comment: Findings K, M and O are examples of where inadequate training and oversight
by the supervisor are apparent.
Documentation
E. Finding: The laboratory needs to document traceability information of purchased materials
and reagents. Cited previously on July 11, 2012 and September 27, 2017.
Requirement: All chemicals, reagents, standards and consumables used by the laboratory
must have the following information documented: Date Received, Date Opened (in use),
Vendor, Lot Number, and Expiration Date. Consumable materials such as pH buffers and
lots of pre -made standards are included in this requirement. Ref: Quality Assurance
Policies for Field Laboratories.
Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A
NCAC 2H .0805 (g) (1).
Comment: A reagent log template was provided at the time of the July 11, 2012 and
September 27, 2017 inspections.
Laboratory Response (2012): The following response was received from the laboratory
via United States Postal Service (USPS) mail on August 27, 2012: "In an effort to
conform to your recommendation all reagents and consumables, i.e. distilled water have
been dated as received on 8/20/12. We will indicate the date that each reagent is
opened per your suggestion. Expiration dates are printed on each label as per the
factory suggested use by date. We do not prepare any solutions from stock in our field
lab".
Laboratory Response (2017): The following response was received from the laboratory
via email on November 17, 2017: "Traceability is now being documented on a reagent
log for the pH buffers and TRC reagents". Supporting documentation was not submitted
with the inspection response. This documentation was submitted via email on January
31, 2018.
Comment: No documentation beyond that submitted on January 31, 2018 could be found
while inspectors were onsite during the March 5, 2019 inspection.
Comment: The pH buffers in use appear to have been poured from large 4-liter containers
into 500 mL containers for daily use. The 500 mL containers were not relabeled with the
correct traceability information (e.g., Date opened, Lot Number, Expiration Date). The 500
mL containers are the same containers (i.e., same manufacturer and lot number) that were
in use during the 2017 inspection.

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#5242 Town of Ansonville WWTP
C. Finding: All original records are not being maintained for five years. Cited previously on
September 27, 2017.
Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A
NCAC 2H .0805 (g) (1).
Comment: At the time of the inspection, benchsheets were found from January 2011
through March 3, 2013 and September 27, 2017 through December 12, 2017. After the
inspection, the laboratory was requested to submit benchsheets from December 2017 to
the date of the request on March 6, 2019. The laboratory supervisor replied via email on
March 7, 2019 that there were no benchsheets for this timeframe. This is in direct conflict
with the response to the 2017 inspection report.
Laboratory Response (2017): On October 4, 2017, prior to issuing the inspection
report, a benchsheet containing compliance data for September 27 and October 3, 2017
was submitted for review. However, some meter calibration times, and sample
collection and analysis times were missing. Another benchsheet with compliance data
for October 10, 12 and 17, 2017 that included all the required documentation was
submitted on October 18, 2017. After receiving the inspection report, the laboratory
submitted the following response via email on November 17, 2017: "All original records
are now being kept for 5 years beginning September 28, 2017".
D. Finding: Sample collection and analysis times for pH, Temperature and Total Residual
Chlorine (TRC) are not documented. Cited previously on July 11, 2012.
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 units of measure for all analyses. Ref: 15A NCAC 2H
.0805 (g) (1).
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Date and time of sample collection; Date and time of sample
analysis - Alternatively, one time may be documented for collection and analysis with the
notation that samples are measured in situ or immediately at the sampling site (i.e.,
immediately following collection at a location as near to the collection point as possible).
When this `one time' option is used, state that the documented time is both collection
and analysis time. Ref: NC WW/GW LC Approved Procedure for the Analysis of
Temperature.
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Date and time of sample collection; Date and time of sample
analysis to verify the 15-minute holding time is met [Alternatively, one time may be
documented for collection and analysis with the notation that samples are measured
immediately at the sample site.] Ref: NC WW/GW LC Approved Procedure for the
Analysis of Total Residual Chlorine and NC WW/GW LC Approved Procedure for the
Analysis of pH.
Comment: A benchsheet was submitted by the laboratory on August 8, 2017 for review,
prior to the September 27, 2017 inspection. A revised benchsheet that included all the
required documentation and traceability information was emailed back to the laboratory on
August 24, 2017. In this email it was stated that, "all the required documentation will need
to be implemented by the scheduled inspection".

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#5242 Town of Ansonville WWTP
Comment: At the time of the inspection there was no documentation found for sample
collection and analysis time of pH, TRC and Temperature. This is in direct conflict with the
response to the 2012 inspection report.
Laboratory Response (2012): The following response was received from the laboratory
via USPS mail on August 27, 2012: "The collection time is currently being reported on
the bench sheets". "We will endeavor to conduct analysis within the holding time limit for
each parameter i.e. pH and CL2".
Proficiency Testing
E. Finding: The preparation of PT Samples is not documented. Cited previously on July
11, 2012 and September 2017.
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 (e.g., pH), but it is recommended that the instructions be
maintained. Ref: Proficiency Testing Requirements, October 29, 2018, Revision 3.
Comment: Dating and initialing the instruction sheet for the preparation of the TRC PT
Sample would satisfy the documentation requirement.
Laboratory Response (2017): The following response was received from the laboratory
via email on November 17, 2017: "There was a misunderstanding in communications
the day of the inspection. I actually have all paperwork for my proficiency testing dated
back to 2009".
Comment: A folder containing PT Sample documents from the PT Provider was
discovered during the March 5, 2019 inspection; however, none of the PT Sample
preparation instruction pages had been initialed and dated by the analyst and no other
documentation of how PT Samples were prepared was found.
F. Finding: The laboratory is not analyzing PT Samples in the same manner as routine
Compliance Samples. Cited previously on July 11, 2012 and September 27, 2017.
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 bV 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. Ref: Proficiency Testing Requirements, October 29, 2018,
Revision 3.
Comment: At the time of the inspection, documentation was found to indicate that a
known sample was being analyzed along with the PT Sample. Documentation was also

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#5242 Town of Ansonville WWTP
discovered showing that PT Samples were being analyzed multiple times and averaged
for reporting. This is in direct conflict with the response to the 2017 inspection report.
Laboratory Response (2012): The following response was received from the laboratory
via USPS mail on August 27, 2012: "The proficiency testing samples are not run in
conjunction with 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." The inspection response was not acceptable due to the
laboratory's apparent intent to continue analyzing additional quality control standards
obtained from the PT Sample Provider. Clarification was requested, and the following
response was received via USPS mail on November 12, 2012. "We will review and seek
to conform to the division's guidance for Proficiency Testing, Dated February 20, 2012.
Please send us a hard copy by return mail for our files".
Laboratory Response (2017): The following response was received from the laboratory
via email on November 17, 2017: "PT Samples are now being treated like the
compliance samples, analyzed once without a known and reported".
G. Finding: The laboratory does not retain all records necessary to facilitate historical
reconstruction of the analysis and reporting of analytical results for PT Samples. Cited
previously on July 11, 2012 and September 27, 2017.
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) (G)] 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, October 29, 2018,
Revision 3.
Comment: PT Sample results are documented directly on PT vendor reporting forms.
This is in direct conflict with the response to the 2017 inspection report.
Laboratory Response (2012): The following response was received from the
laboratory via USPS mail on August 27, 2012: "Our results for Proficiency Testing are
recorded on the ERA report sheets which are filed for the required period of 5 years. We
did included (sic) Proficiency Testing results on our bench sheet dated July 24, 2012".
Laboratory Response (2017): The following response, along with a benchsheet
showing the documentation of the 2017 PT samples analyses was received from the
laboratory via email on October 3, 2017: "PT samples are now being documented on the
benchsheet like compliance samples".
Temperature — Standard Methods, 2550 B-2000 (Aqueous)
Comment: At the time of the inspection, the analyst stated that a thermometer is being used to
measure the effluent temperature at the time contracted samples are collected. A subsequent
check of the Chain of Custody (COC) for the day of the inspection showed nothing documented in
the space for the temperature at the time of sample collection. A reply to the September 27, 2017
inspection indicated that Temperature was being measured with the pH meter. When asked about
the apparent discrepancy, Ms. McLaughlin stated in an email received on March 19, 2019 that

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#5242 Town of Ansonville WWTP
temperature measurements were being made with a hand-held thermometer at the sampling site
and documented only on the DMR.
H. Finding: The thermometer used to measure temperature values has not been checked
against a National Institute of Standards and Technology (NISI) traceable thermometer
every 12 months. Cited previously on September 27, 2017.
Requirement: All thermometers and temperature measuring devices used for
compliance monitoring must be checked every 12 months against a NIST traceable
temperature measuring device and the process documented. NIST traceable
temperature measuring devices used for this verification must have a stated accuracy of
at least ± 0.5 °C. The thermometer/meter readings on the meter being checked must be
less than or equal to 0.5°C from the NIST traceable temperature measuring device
reading. The calibration verification documentation must include the serial number of the
thermometer/meter being checked and the NIST traceable temperature measuring
device that was used in the comparison. Document the verification data and keep on file.
Ref: NC WW/GW LC Approved Procedure for the Analysis of Temperature.
Comment: This Finding also applies to the hand-held thermometer that was currently in
use. Ms. McLaughlin confirmed in an email on March 20, 2019 that the hand-held
thermometer had never been verified against an NIST traceable temperature -measuring
device and its stated accuracy is unknown.
Laboratory Response (2017): The following response was received from the laboratory
via email on November 17, 2017: "Enclosed is copy of the temperature sensor
verification that was done on the pH meter". The temperature sensor verification was
unacceptable a revised temperature sensor verification was submitted on August 20,
2018. At the time of this inspection the pH meter was being used for Temperature
measurement.
Chlorine, Total Residual — Standard Methods, 4500 Cl G-2000 (Aqueous)
Comment: While inspectors were on site, the back-up analyst brought an effluent sample into
the laboratory to be analyzed for TRC. The inspectors observed that analysis. The analyst did
not perform a calibration verification. When the buffer and color reagent were added to the
sample, it immediately turned a rich pink color, indicating a high concentration of residual
chlorine. The analyst read the sample on the regular -level program #80. The inspector
observed a concentration of 9.8 mg/L on the meter display and commented on the high
concentration. That concentration far exceeds the facility's permitted discharge limit of 28 pg/L.
The analyst stated that he had mistakenly read the sample on the wrong meter program. He
switched the meter to the low-level program #86 and poured another sample aliquot to analyze.
Upon the addition of buffer and color reagent, the sample again turned a rich pink color. The
meter displayed "over range" when this sample was read on the low-level meter program. The
maximum range of the low-level program is 500 pg/L (0.5 mg/Q. The analyst stated that sample
concentrations were not usually that high and that he must have done something wrong when
collecting the sample. The inspectors accompanied the analyst back to the sampling site to
collect another sample. Another sample was collected, and the inspectors noticed nothing
wrong with the collection technique. However, it was noted that the analyst did not document
the collection time. The sample again turned a rich pink color upon addition of the buffer and
color reagent and read "over range" on the low-level program. It was also noted that the analyst
did not wait the method -required three -minute minimum for the color to develop. When asked
about the wait time, the analyst seemed unsure about how long he was supposed to wait before
reading the result.

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#5242 Town of Ansonville WWTP
I. Finding: The laboratory is not verifying the instrument's Factory -set Calibration Curve
every 12 months. Cited previously on July 11, 2012.
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 Reagent 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 lag/L and must not vary by more than 25% from the known value for standard
concentrations less than 50 lag/L. Ref: NC WW/GW LC Approved Procedure for the
Analysis of Total Residual Chlorine.
Comment: The laboratory has not verified the instrument's Factory -set Calibration Curve
since July 5, 2017. The last documented verification of the Factory -set Calibration Curve
prior to this date was September 20, 2012.
Laboratory Response (2012): The following response was received from the laboratory
via USPS on August 27, 2012: "It is our understanding that the Hach 2500 Laboratory
Spectrophotometer has an on board curve that does not need to be corrected. However,
we will schedule a time convenient for Ms. Sylvia Jeter to assist Dianna McLaughlin in
conducting an analyst specific curve on this instrument". Documentation of a calibration
curve verification was submitted on October 9, 2012.
J. Finding: The laboratory is not verifying the Gel® Standard concentration every 12
months. Cited previously on July 11, 2012 and September 27, 2017.
Requirement: 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. Ref: NC WW/GW LC Approved
Procedure for the Analysis of Total Residual Chlorine. Please submit a copy of the
Gel® Standard verification with the report reply.
Comment: The Gel® Standard had not been verified since the September 27, 2017
inspection. The last documented Gel® Standard verification prior to this date was
September 20, 2012.
Laboratory Response (2012): The following response was received from the laboratory
via USPS on August 27, 2012: "We will verify on the next bench sheet. For the month of
August 2012, we have complied with your suggestion. A copy of the gel verification was
submitted on October 9, 2012.
Laboratory Response (2017): The following response was received from the laboratory
via email on November 17, 2017: "Gel standard was verified and assigned a true value
on September 27, 2017. Decided to put on same schedule as the curve on September
27, 2017 but will be verified again once new curve is done and assigned a new true
value".
Comment: A copy of the Approved Procedure for the Analysis of Total Residual
Chlorine was given to the laboratory at the time of the inspections on July 11, 2012 and
September 27, 2017.

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#5242 Town of Ansonville WWTP
K. Finding: The meter is not being zeroed with a calibration blank each day samples are
analyzed. Cited previously on September 27, 2017.
Requirement: Analyze a calibration blank to zero the instrument and analyze a check
standard each day that samples are analyzed. Ref: NC WW/GW LC Approved Procedure
for the Analysis of Total Residual Chlorine.
Comment: The gel -type standard blank can be used as the calibration blank.
Laboratory Response (2017): The following response was received from the laboratory
via email on November 17, 2017: "Meter is now being zeroed using the gel standard
beginning on September 28, 2017".
L. Finding: The calibration curve is not verified with a check standard each day that samples
are analyzed. Cited previously on September 27, 2017.
Requirement: When a five -standard annual standard curve verification is used, the
laboratory must check the calibration curve each analysis day. To do this, the laboratory
must analyze a calibration blank to zero the instrument and analyze a check standard each
day that samples are analyzed. The value obtained for the check standard must read within
10% of the true value of the 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 Total Residual Chlorine.
Comment: The analyst seemed unaware that the meter must be calibrated prior to sample
analysis. When asked about calibrating the meter, the analyst stated that he thought his
supervisor calibrated it at least once year. This is in direct conflict with the response to the
2017 inspection report.
Laboratory Response (2017): The following response was received from the laboratory
via email on November 17, 2017: "A check standard is now being analyzed each
analysis day prior to analyzing samples. A benchsheet was submitted on October 18,
2017 showing this is being done".
M. Finding: Values less than the established reporting limit are being reported on the
Discharge Monitoring Reports (DMR).
Requirement: The concentrations of the calibration standards must bracket the
concentrations of the samples analyzed. One of the standards must have a
concentration equal to or below the lower reporting concentration for Total Residual
Chlorine. The lower reporting limit must be less than or equal to the permit limit. Ref: NC
WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine.
Comment: The laboratory established a lower reporting limit of 25 pg/L on July 5, 2017.
Values with concentrations less than that must be reported as <25 pg/L on the DMR.
However, the laboratory is reporting <20 pg/L on the DMR, which was the lower reporting
limit established by the 2008 Factory -set Calibration Curve verification.
pH — Standard Methods, 4500 H+ B-2011 (Aqueous)
N. Finding: The pH meter is not calibrated prior to analysis of samples each day
compliance monitoring is performed.

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#5242 Town of Ansonville WWTP
Requirement: Instruments are to be calibrated according to the manufacturer's
calibration procedure prior to analysis of samples each day compliance monitoring is
performed. Calibration must include at least two buffers. The meter calibration must be
verified with a third standard buffer solution (i.e., check buffer) prior to sample analysis.
The calibration and check standard buffers must bracket the range of the samples being
analyzed. Ref: NC WW/GW LC Approved Procedure for the Analysis of pH.
Comment: While inspectors were on site, the analyst brought an effluent sample into
the laboratory to be analyzed for pH. The inspectors observed that analysis. The
analyst did not calibrate the meter prior to analyzing the sample. The analyst seemed
unaware that the meter must be calibrated prior to sample analysis. When asked about
calibrating the meter, the analyst stated that he thought his supervisor calibrated it at least
once year.
O. Finding: The laboratory is not analyzing a check standard buffer after calibration and
prior to sample analysis.
Requirement: Instruments are to be calibrated according to the manufacturer's
calibration procedure prior to analysis of samples each day compliance monitoring is
performed. Calibration must include at least two buffers. The meter calibration must be
verified with a third standard buffer solution (i.e., check buffer) prior to sample analysis.
Ref: NC WW/GW LC Approved Procedure for the Analysis of pH.
P. Finding: Samples are not gently stirred during measurement.
Requirement: Samples shall be gently stirred during measurement. The pH sensing
porting and the reference junction must be completely immersed. Steps must be taken to
eliminate cross contamination between measurements (e.g., rinsing and blotting the
electrode dry, dipping the electrode in stream multiple times, etc.). Ref: NC WW/GW LC
Approved Procedure for the Analysis of pH.
Comment: While inspectors were on site, the analyst brought an effluent sample into
the laboratory to be analyzed for pH. The inspectors observed that analysis. The pH
probe was inserted directly into the sample container and the sample was not stirred or
agitated while the meter attempted to stabilize the reading. The analyst seemed
unaware of this requirement, when asked. No stir plates were observed in the area
where analyses are performed.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water
Resources. Data were reviewed for the Town of Ansonville WWTP for (NPDES # NC0081825)
for October 2017. The following errors were noted:
Date
Parameter
Location
Value on
Benchsheet
Value on
DMR
10/10/2017
Temperature
Effluent
370C
250C
10/10/2017
pH
Effluent
6.89 S.U.
7.2 S.U.
10/12/2017
Temperature
Effluent
40.1 °C
250C

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#5242 Town of Ansonville WV TP
10/12/2017
pH
Effluent
6.88 S.U.
7.2 S.U.
10/17/2017
Temperature
Effluent
44.6°C
250C
10/17/2017
pH
Effluent
7.67 S.U.
7.2 S.U.
Comment: It was noted that all pH values reported during the months of October and November
2017 were exactly 7.2 S.U. It seems unlikely that the pH of the effluent would not vary over a two -
month time period.
Comment: Contradictory values and the lack of supporting documentation for data reported on
the DNIR could give the perception of falsified data. Falsified data or information is defined in NC
Administrative Code 15A NCAC 02H .0803 (6) as "data or information which has been made
untrue by alteration, fabrication, omission, substitution, or mischaracterization".
We are concerned with the Findings that were cited previously and not corrected. The number
and severity of the Findings; which have not been corrected even after the laboratory stated
corrective actions had been implemented, make the validity of reported data suspect.
Decertification for all parameters will be recommended for the infractions listed below.
Laboratory Decertification Ref: 15A NCAC 2H .0807 (a) (1), (2), (10), (13) and (14):
A laboratory may be decertified for any or all parameters for up to one year for any or all of the
following infractions:
(1) Failing to maintain the facilities, or records, or personnel, or equipment, or quality control
program as set forth in the application, and these Rules; or
(2) Submitting inaccurate data or other information; or
(10) Failing to supply analytical data requested by the State Laboratory; or
(13) Failing to respond to requests for information by the date due; or
(14) Failing to comply with any other terms, conditions, or requirements of this Section or of a
Laboratory certification.
Civil Penalties Ref: 15A NCAC 02H .0807 (f):
Civil penalties may be assessed against a laboratory which violates or fails to act in accordance
with any of the terms, conditions, or requirements of the Rules in this Section or of a laboratory
certification. A laboratory is subject to both civil penalties and decertification.
Report prepared by: Tonja Springer Date: March 14, 2019
Report reviewed by: Todd Crawford and Beth Swanson Date: March 22, 2019

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