#5405_2018_1114_TS_FINAL

Laboratory Cert. #:
5405
Laboratory Name:
Town of Pittsboro Water Treatment Plant
Inspection Type:
Field Municipal Maintenance
Inspector Name(s):
Tonja Springer
Inspection Date:
November 14, 2018
Date Forwarded for Initial
Review:
December 11, 2018
Initial Review by:
Jason Smith
Date Initial Review
Completed:
December 11, 2018
Cover Letter to use:
❑ Insp. Initial ® Insp. Reg
❑Insp. No Finding ❑Insp. CP
❑Corrected ❑Insp. Reg. Delay
(to use: rt click, properties, check)
Unit Supervisor/Chemist III:
Todd Crawford
Date Received:
December 11, 2018
Date Forwarded to Admin.:
December 13, 2018
Date Mailed:
December 19, 2018
Special Mailing Instructions:

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5405
Mr. Curtis Hall
Town of Pittsboro Water Treatment Plant
P. O. Box 759
Pittsboro, NC 27312
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December 19, 2018
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Hall:
Enclosed is a report for the inspection performed on November 14, 2018 by Tonja Springer. 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].
Sincerely,
Todd Crawford
Technical Assistance & Compliance Specialist
NC WW/GW Laboratory Certification Branch
Attachment
cc: Dana Satterwhite, Tonja Springer, Master File #5404
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North Carolina Department of Environmental Quality I Division of Water Resources
1623 Mail Service Center I Raleigh, North Carolina 27699-1623
Phone [phone]/rax 919,733.6241

LABORATORY NAME:
NPDES PERMIT :
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
I. INTRODUCTION:
Town of Pittsboro Water Treatment Plant
NC0080896
3746 Hwy 15 501 N.
Pittsboro, NC 27312
5405
November 14, 2018
Field Municipal Maintenance
Tonja Springer
Curtis Hall
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. Records are well organized and easy to retrieve. Staff were forthcoming and seemed
eager to adopt necessary changes.
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 Environmental Conservation Laboratories, Inc.
(Certification #591) and Research & Analytical Laboratories (Certification #34).
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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#5405 Town of Pittsboro Water Treatment Plant
data. It is not intended to imply that existing records are not adequately maintained unless the
Finding speaks directly to that.
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).
B. Finding: The laboratory benchsheet for pH and Total Residual Chlorine (TRC) is
lacking pertinent data: Time of sample analysis, sample site (ID or location), permit
number, meter calibration time, units of measure, instrument identification and method
reference.
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 bench sheets must provide a space for the signature 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: Time of sample analysis, sample site (ID or location), permit
number, meter calibration times, units of measure, instrument identification (serial
number preferred) and method reference. Ref: NC WW/GW LC Approved Procedure for
the Analysis of pH and NC WW/GW LC Approved Procedure for the Analysis of Total
Residual Chlorine.
Comment: The benchsheet header is "Ultra Low Benchsheet" and it includes TRC and pH
results. However, the laboratory is documenting only one time for sample analysis. The
time documented is for the TRC analysis but it is not clearly documented. The pH sample
analysis time is not documented.
C. Finding: The three gel -type standard values used to obtain the true value are not
documented. This is considered pertinent data.
Requirement: To assign a true value to the gel -type or sealed liquid standard: 1. Zero
the instrument with the calibration blank. 2. Read and record gel standard values. 3.
Repeat steps 1 and 2 at least two more times. 4. Assign the average value as the true
value. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual
Chlorine.

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#5405 Town of Pittsboro Water Treatment Plant
Requirement: Data pertinent to each analysis must be maintained for five years. Ref:
15A NCAC 2H .0805 (g) (1).
Quality Control
D. Finding: The laboratory is not calibrating the mechanical pipettors every 12 months.
Requirement: Mechanical volumetric liquid -dispensing devices (e.g., fixed and
adjustable auto-pipettors, bottle -top dispensers, etc.), used for critical measurements,
must be calibrated at least every twelve months and documented. Each liquid -
dispensing device must meet the manufacturer's statement of accuracy. For variable
volume devices used at more than one setting, check the accuracy at the maximum,
middle and minimum values. Testing at more than three volumes is optional. When a
device capable of variable settings is dedicated to dispense a single specific volume,
calibration is required at that setting only. Ref: Quality Assurance Policies for Field
Laboratories.
Proficiency Testing
E. 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 (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 TRC for the laboratory's currently certified
parameters. Dating and initialing the instruction sheet for each prepared PT Sample would
satisfy the documentation requirement.
F. 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.
Chlorine, Total Residual — Standard Methods, 4500 CI G-2011 (Aqueous)
G. Finding: Samples are being filtered without documentation.

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#5405 Town of Pittsboro Water Treatment Plant
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Statement that samples were filtered, when applicable. Ref: NC
WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine.
Requirement: For all calibration options, if routine compliance samples are filtered, the
calibration/calibration verification standards must also be filtered using a 3-micron
membrane filter. This is to demonstrate that the filtration process does not remove any
chlorine. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual
Chlorine.
H. Finding: The laboratory is not analyzing a reagent blank with prepared standards.
Requirement: If preparing standards, analyzing a PT Sample or analyzing diluted
samples, a Reagent Blank is required. Ref: NC WW/GW LC Approved Procedure for the
Analysis of Total Residual Chlorine.
Comment: A Reagent Blank is made from the same laboratory water source used to
make liquid standards. The concentration of Reagent Blanks must not exceed 50% of the
reporting limit (i.e., the lowest calibration or calibration verification standard concentration)
or corrective action must be taken.
I. Finding: Values less than the established reporting limit are being reported on the
Discharge Monitoring Report (DMR)
Requirement: For all calibration options, the range of standard concentrations must
bracket the permitted discharge limit concentration, the range of sample concentrations to
be analyzed and anticipated PT Sample concentrations. One of the standards must have
a concentration equal to or less than the permitted discharge limit. The lower reporting
limit concentration is equal to the lowest standard concentration. Sample concentrations
that are less than the lower reporting limit must be reported as a less -than value. Ref: NC
WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine.
Comment: The concentration of the lowest standard analyzed for the annual factory -set
calibration curve verification was 10 pg/L. However, the laboratory is reporting sample
concentrations below this value on the DMR. The laboratory must report any value less
than the lowest standard concentration as < 10 pg/L.
pH — Standard Methods, 4500 H+B-2011 (Aqueous)
J. 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. All check
standard buffers must read within ±0.1 S.U. to be acceptable. Ref: NC WW/GW LC
Approved Procedure for the Analysis of pH.
IV. PAPER TRAIL INVESTIGATION:

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#5405 Town of Pittsboro Water Treatment Plant
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
Resources. Data were reviewed for the Town of Pittsboro Water Treatment Plant (NPDES
permit # NC0080896) for January, July and September 2018. No transcription errors were
observed. The facility appears to be doing a good job of accurately transcribing data.
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: Tonja Springer Date: December 11, 2018
Report reviewed by: Jason Smith Date: December 11, 2018

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