#5022_03_2015_FINAL

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
Laboratory Name:
Inspection Type:
Inspector Name(s):
Inspection Date:
Date Report Completed:
Date Forwarded to Reviewer:
Reviewed by:
Date Review Completed:
Cover Letter to use:
Unit Supervisor/Chemist III:
Date Received:
Date Forwarded to Linda:
Date Mailed:
5022
Town of Columbus WWTP
Field Maintenance
Jason Smith
March 17, 2015
April 10, 2015
April 10, 2015
Nick Jones
April 13, 2015
❑ Insp. Initial
❑ Insp. No Finding
❑ Corrected
® Insp. Reg.
❑ Insp. CP
❑ Insp. Reg. Delay
Gary Francies
4/13/2015
4/16/2015
4/16/15 Ic

LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
On -Site Inspection Report
Town of Columbus WWTP
NCO021369
P.O. Box 146
Columbus, NC 28722
5022
March 17, 2015
Field Maintenance
Jason Smith
LOCAL PERSON(S) CONTACTED: Jason Phillips and Michael Fife
INTRODUCTION:
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.
GENERAL COMMENTS:
The facility has all the equipment necessary to perform the analyses. Proficiency Testing (PT) samples
for the 2015 proficiency testing calendar year have not yet been analyzed. The laboratory is reminded
that these results must be submitted to this office directly from the vendor by September 30, 2015.
Contracted analyses are performed by Environmental Testing Solutions, Inc. (Certification #600).
Current quality assurance policies for Field Laboratories and approved procedures for the analysis of
the facility's currently certified parameters were provided at the time of the inspection.
The previous Operator in Responsible Charge (ORC) left the facility in mid -February without training
Mr. Phillips, the current ORC. Mr. Phillips requested an inspection to receive technical assistance and
ensure compliance with certification rules.
FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
Comment: The laboratory was not reporting all data analyzed on the Discharge Monitoring Report
(DMR). The North Carolina Administrative Code, 15A NCAC 2B .0506 (b) (3) (J) states: The results of
all tests on the characteristics of the effluent, including but not limited to NPDES permit monitoring
requirements, shall be reported on the monthly report forms. During the inspection and prior to the
Paper Trail Investigation, Janet Cantwell with the Division of Water Resources called to notify the
laboratory of permit monitoring frequency violations. Temperature, pH, Dissolved Oxygen (DO), and Total
Residual Chlorine (TRC) were analyzed twice each week, but only one value for each parameter was
reported each week. This occurred from June, 2014 through January, 2015. Laboratory personnel

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#5022 Town of Columbus WWTP
indicated to Ms. Cantwell and me that they will submit amended DMRs to address the unreported data.
Although the February, 2015 DMR had not been submitted, all data was recorded on it as required prior
to the inspection. No further response is necessary for this finding.
A. Finding: The laboratory needs to increase the documentation 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. Consumable materials such as pH buffers and lots
of pre -made standards are included in this requirement. Ref: Quality Assurance Policies for
Field Laboratories.
Comment: An example traceability log was emailed to the facility on April 10, 2015.
Implementation of this log will fulfill this requirement.
B. Finding: Error corrections are not performed properly.
Requirement: All documentation errors must 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. Write the correction adjacent to the error. The correction must be initialed
by the responsible individual and the date of change documented. All data and log entries must
be written in indelible ink. Pencil entries are not acceptable. Ref: Quality Assurance Policies for
Field Laboratories.
Comment: Some error corrections were made by overwriting of the original data. Error
corrections were not dated and initialed.
Total Residual Chlorine — Standard Methods, 4500 CI G-2000
Dissolved Oxygen — Standard methods, 4500 O G-2001
PH — Standard Methods, 4500 H+ B-2000
PH — SW-846 9040 C
PH — SW-846 9045 D
Temperature — Standard methods, 2550 B-2000
C. Finding: The laboratory benchsheet was lacking pertinent data: Instrument identification.
Requirement: The following must be documented in indelible ink whenever sample analysis is
performed: Instrument Identification. Ref: NC WW/GW LC Approved Procedure for the Analysis
of Total Residual Chlorine, NC WW/GW LC Approved Procedure for the Analysis of Dissolved
Oxygen, NC WW/GW LC Approved Procedure for the Analysis of pH, NC WW/GW LC Approved
Procedure for the Analysis of Temperature.
D. Finding: The sample collector and analyst were not clearly identified.
Requirement: Data pertinent to each analysis must be maintained for five years. Certified Data
must consist of date collected, time collected, samples site, sample collector, and sample
analysis time. The field benchsheets 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).

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#5022 Town of Columbus WWTP
Comment: The initials for both operators on site were documented. This does not clearly show
who collected and analyzed the samples.
Comment: Initials are sufficient to fulfill the requirement of a signature.
E. Finding: Sample collection and analysis times are not clearly documented.
Requirement: Data pertinent to each analysis must be maintained for five years. Certified Data
must consist of date collected, time collected, samples site, sample collector, and sample
analysis time. The field benchsheets 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).
Comment: Only analysis time is currently documented. Temperature, pH, and Dissolved Oxygen
(DO) are analyzed immediately. For these parameters, the benchsheet can be labeled
It time" or a comment can be added to the benchsheet to indicate that samples
are analyzed in situ. Total Residual Chlorine is collected and transported to the laboratory for
analysis. In that case, collection and analysis times must be documented in order to demonstrate
that the fifteen minute holding time is being met.
pH — Standard Methods, 4500 H+ B-2000
F. Finding: Values 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-2000, (6).
Recommendation: Although this is not required for sludge analyses (SW-846 9040 C and
9045 D), it is recommended that these results be rounded to the nearest 0.1 unit as well for
consistency.
PH — SW-846 9040 C
PH — SW-846 9045 D
G. Finding: Collection and analysis times were not documented for sludge analyses.
Requirement: Data pertinent to each analysis must be maintained for five years. Certified Data
must consist of date collected, time collected, samples site, sample collector, and sample
analysis time. The field benchsheets 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).
H. Finding: Sludge sample measurements are not bracketed with calibration and check standard
buffers.
Requirement: Each instrument/electrode system must be calibrated at a minimum of two points
that bracket the expected pH of the samples and are approximately three pH units or more
apart. Ref: EPA SW-846 Test Methods for Evaluating Solid Waste, Physical/Chemical Methods;
3 Edition, Method 9040 C. Rev. 3. November 2004. Section 7.1.2. EPA SW-846 Test Methods
for Evaluating Solid Waste, Physical/Chemical Methods; 3`d Edition, Method 9045 D. Rev. 4.
November 2004. Section 7.1.2.

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#5022 Town of Columbus VWVfP
Comment: In order to meet this requirement for sludge samples, a standard at or above 12.45
Standard Units (SU) must be checked.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing field testing records 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 Columbus WWTP (NPDES permit #NC0021369) for October, November,
December, 2014, and February, 2015. No transcription errors were detected. The facility appears to be
doing a good job of accurately transcribing data.
V. CONCLUSIONS:
Correcting the above -cited findings will help this lab to produce quality data and meet certification
requirements. The inspector would like to thank the staff for its assistance during the inspection and
data review process. Please respond to all findings and include an implementation date for each
corrective action.
Report prepared by: Jason Smith Date: April 10, 2015
Report reviewed by: Nick Jones Date: April 13, 2015

' • fir% /':,
NCDENF
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
April 16, 2015
5022
Mr. Jason Phillips
Town of Columbus WWTP
P.O. Box 146
Columbus, NC 28722
Donald R. van der Vaart
Secretary
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Phillips:
Enclosed is a report for the inspection performed on March 17, 2015 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. '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.
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 us at (828)
296-4677.
Attachment
cc: Master file
Jason Smith
Sincerely,
Gary Francies, Technical Assistance/Compliance Specialist
Division of Water Resources
Water Sciences Section
NC Wastewater/Groundwater Laboratory Certification Branch
1623 Mail Service Center; Raleigh, North Carolina 27699-1623
Location: 4405 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone]tFAX: 919-733-6241
Internet: wvvw.dwgiab.orq
An Equal Opportunity\ Affirmative Action Employer