#5109_2018_0823_JS_FINAL

Laboratory Cert. :
5109
Laboratory Name:
Town of Old Fort WWTP
Inspection Type:
Field Municipal Maintenance
Inspector Name(s):
Jason Smith
Inspection Date:
August 23, 2018
Date Forwarded for Initial
Review:
September 18, 2018
Initial Review by:
Tonja Springer
Date Initial Review
Completed:
September 19, 2018
Cover Letter to use:
❑ Insp. Initial ® Insp. Reg
[]Insp, No Finding P
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❑Corrected ❑Insp. Reg. Delay
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Unit Supervisor/Chemist III:
Todd Crawford
Date Received:
September 19, 2018
Date Forwarded to Admin.:
September 20, 2018
Date Mailed:
Special Mailing Instructions:

Water f?esour-ce5
FNVtR0NMENT ,L QU h, k_ITY
September 20, 2018
5109
Mr. Tony West
Town of Old Fort WWTP
38 Catawba Ave
Old Fort, NC 28762
ROY COOPER
MICHEAL S. REGAN
LINDA CULPEPPER
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. West:
Enclosed is a report for the inspection performed on August 23, 2018 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 21-1.0800.
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].
Sincerely,
Todd Crawford
Technical Assistance & Compliance Specialist
NC WW/GW Laboratory Certification Branch
Attachment
cc: Dana Satterwhite, Jason Smith, Master File #5109
Water Sciences Section
NC WastewaterlCaroundwater Laboratory Certification Branch
623 P, afi S rdi- Center. Rafe qh. North Carolina 2 699-try5�23
catim 4405 Reedy Creek Road,R.alegh, Noi�h Carolina 27607
Phone:9''9-733-3908 PAX 919-733-324
nzernet {l t.re.gov,labouJgiarsionstvwater-reso�irces/water•resources•datalwater-sciences-hone-pvgella��i¢ica?icn-tranch
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CERTIFICATE #:
Town of Old Fort WWTP
NC0021229
1174 E. Main St.
Old Fort, NC 28762
5109
August 23, 2018
Field Municipal Maintenance
Jason Smith
Tony West and Aaron Vess
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 compliance monitoring samples.
II. GENERAL COMMENTS:
The facility is neat and well organized and has all the equipment necessary to perform the
analyses. Benchsheets are well designed, easy to follow and concise. Records are well
organized and easy to retrieve.
All required Proficiency Testing (PT) Samples have been analyzed for the 2018 PT Calendar Year
and the graded results were 100% acceptable.
Contracted analyses are performed by Water Tech Labs, Inc. (Certification #50) and
Environmental Testing Solutions, Inc. (Certification #600).
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 the
inspection.
Requirements that reference 15A NCAC 2H .0805 (g) (1), stating "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", are
intended to be a requirement to document all pertinent information for historical reconstruction of

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#5109 Town of Old Fort WWTP
data. It is not intended to imply that existing records are not adequately maintained unless the
Finding speaks directly to that.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS_
Documentation
A. Finding: The laboratory needs to document traceability information of purchased
materials and reagents.
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. A system (e.g., traceable identifiers)
must be in place that links standard/reagent preparation information to analytical batches
in which the solutions are used. 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).
Proficiency Testing
B. 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 loq 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, May 31, 2017, Revision 2.0.
Comment: This Finding only applies to Total Residual Chlorine for the laboratory's
currently certified parameters. Dating and initialing the instruction sheet for each prepared
PT Sample would satisfy the documentation requirement.
C. 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, May 31, 2017, Revision 2.0.
Comment: The analysis of PT Samples is designed to evaluate the entire process used to
routinely report Compliance Sample results; therefore, PT Samples must be analyzed and
the process documented in the same manner as Compliance Samples.
Comment: The laboratory was only documenting the results on the form submitted to the
vendor.

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#5109 Town of Old Fort WWTP
M
D. Finding: The laboratory is not analyzing PT Samples in the same manner as routine
Compliance 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.
Laboratories must document any exceptions. 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, May 31, 2017, Revision 2.0.
Comment: The laboratory's common practice was to analyze a known standard along
with the PT Sample as additional QC. Since this is not performed with all Compliance
Samples, it is considered additional QC. However, additional QC is recommended as part
of the troubleshooting and corrective action process, prior to analyzing remedial PT
Samples.
Comment: The laboratory was also analyzing PT Samples multiple times and reporting an
average of all results. Compliance samples are not analyzed and reported in this manner.
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 the Town of Old Fort WWTP
(NPDES permit # NC0031879) for January, March and June 2018. The following error was
noted:
Date
Parameter
Location
Value on
Value on eDMR
Benchsheet
6/26/2018
pH
Effluent
7.2 S.U.
7.4 S.U.
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.
V. CONCLUSIONS:
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: Jason Smith
Report reviewed by: Tonja Springer
Date: September 18, 2018
Date: September 19, 2018

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