#5123_10_14_FINAL

RCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
November 20, 2014
5123
Mr. Joe Roberts
Town of Snow Hill WWTP
201 N. Greene St.
Snow Hill, NC 28580
John E, Skvarla, III
Secretary
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Roberts:
Enclosed is a report for the inspection performed on October 22, 2014 by Nick Jones. 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: Nick Jones
Master File
Sincerely,
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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] PAX: 919.733-6241
Internet: www,dwglab,org
An Equal Opportunity i Alfiimallve Adloh F nployor

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
LaboratoryName:
Inspection Type:
Inspector Name(s):
Inspection Date:
Date Report Completed:
Date Forwarded to Reviewer:
Reviewed by:
Date Review Completed:
5123
of Snow Hill VWVfP
Field Maintenance
Nick Jones
October 22 2014
November 12 2014
November 12. 2014
Jason Smith
November 17. 2014
Cover Letter to use: ❑ Insp. Initial ® Insp. Reg.
❑ Insp. No Finding ❑ Insp. CP
❑ Corrected ❑ Insp. Reg. Delay
Unit Supervisor/Chemist III:
Date Received:
Date Forwarded to Linda:
Date Mailed:
Gary Francies
11 /17/2014
11 /20/2014 �,�

LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
On -Site Inspection Report
Town of Snow Hill WWTP
NC0020842
201 N. Greene St.
Snow Hill, NC 28580
5123
October 22, 2014
Field Maintenance
Nick Jones
LOCAL PERSON(S) CONTACTED: Joe Roberts
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.
II. GENERAL COMMENTS:
The facility has all the equipment necessary to perform the analyses.
Proficiency Testing (PT) samples have been analyzed for all certified parameters for the 2014 proficiency
testing calendar year and the graded results were 100% acceptable.
Contracted analyses are performed by Environment 1, Inc. (Certification #10).
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 requirements associated with Findings A and B have been implemented by our program since the
last inspection.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
Comment: Error corrections were not performed properly. The Quality Assurance Policies for Field
Laboratories document states: 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. This requirement is a new policy that has been
implemented by our program since the last inspection. Notification of acceptable corrective action (i.e.,
a statement that meets NC WW/GW LC requirements describing the lab's new protocol for error
corrections) was received by email on 11/10/2014. No further response is necessary for this finding.

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#5123 Town of Snow Hill WWTP
Comment: The laboratory needed to increase the documentation of purchased materials and
reagents, as well as documentation of standards and reagents prepared in the laboratory. The Quality
Assurance Policies for Field Laboratories document states: 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. Documentation of solution preparation must include the analyst's initials, date of
preparation, the volume or weight of standard(s) used, the solvent and final volume of the solution.
This information as well as the vendor and/or manufacturer, lot number, and expiration date must be
retained for chemicals, reagents, standards and consumables used for a period of five years.
Consumable materials such as pH buffers and lots of pre -made standards are included in this
requirement. This requirement is a new policy that has been implemented by our program since the
last inspection. Notification of acceptable corrective action (i.e., the traceability log provided during the
inspection, that contains spaces for all the required items, has been implemented) was received by
email on 11/10/2014. No further response is necessary for this finding.
Comment: The facility name and instrument identification were not documented on the benchsheets for
Dissolved Oxygen, Temperature, pH and Total Residual Chlorine. The NC WW/GW LC Approved
Procedure for the Analysis of Dissolved Oxygen, NC WW/GW LC Approved Procedure for the Analysis
of Temperature, 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 state: The following must be
documented in indelible ink whenever sample analysis is performed: Instrument identification, Facility
Name. This requirement is a new policy that has been implemented by our program since the last
inspection. Notification of acceptable corrective action (i.e., the benchsheets provided by the inspector
during the inspection, that contain spaces for these items, have been implemented) was received by
email on 11/10/2014. No further response is necessary for this finding.
Comment: The value obtained for the reagent blank was not documented on the benchsheets for Total
Residual Chlorine. The NC WW/GW LC Approved Procedure for the Analysis of Total Residual
Chlorine states: The following must be documented in indelible ink whenever sample analysis is
performed: Value obtained for reagent blank. This requirement is a new policy that has been
implemented by our program since the last inspection. Notification of acceptable corrective action (i.e.,
the benchsheets provided by the inspector during the inspection; that contains a space for value
obtained for the reagent blank, have been implemented) was received by email on 11/10/2014. No
further response is necessary for this finding.
Proficiency Testing
A. Finding: The preparation of Proficiency Testing (PT) samples is not documented.
Requirement: PT samples received as ampules must be diluted according to the PT provider's
instructions. The preparation of PT samples must be documented in a traceable log or other
traceable format. The diluted PT sample becomes a routine environmental sample and is added
to a routine sample batch for analysis. Ref: Proficiency Testing Requirements, February 20,
2012, Revision 1.2.
Comment: Dating and initialing the instruction sheet for the preparation of the Total Residual
Chlorine PT would satisfy the documentation requirement.
B. Finding: The laboratory is not documenting Proficiency Testing (PT) sample analyses in the
same manner as environmental samples.

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#5123 Town of Snow Hill WWTP
Requirement: All PT sample analyses must be recorded in the daily analysis records as for any
environmental sample. This serves as the permanent laboratory record. Ref: Proficiency
Testing Requirements, February 20, 2012, Revision 1.2.
Comment: The analysis of PT samples is designed to evaluate the entire process used to
routinely report environmental analytical results; therefore, PT samples must be analyzed and
the process documented in the same manner as environmental samples.
Total Residual Chlorine — Standard Methods, 4500 CI G-2000
C. Finding: The laboratory is not verifying the instrument's factory set curve every 12 months.
Requirement: Analyze a water blank to zero the instrument and then analyze a series of five
standards. The curve verification must check 5 concentrations (not counting the blank) that
bracket the range of the samples to be analyzed. This type of curve verification must be
performed at least every 12 months. The values obtained must not vary by more than 10% of
the known value for standard concentrations greater than or equal to 50 µg/L and must not vary
by more than 25% of the known value for standard concentrations less than 50 µg/L. The
overall correlation coefficient of the curve must be >_0.995. Ref: NC WW/GW LC Approved
Procedure for the Analysis of Total Residual Chlorine.
Comment: The last curve verification was performed on 3/5/2013.
D. Finding: The annual calibration curve verification does not bracket the concentration of the
annual Proficiency Testing (PT) samples.
Requirement: For analytical procedures requiring analysis of a series of standards, the
concentrations of those standards must bracket the concentration of the samples analyzed. One
of the standards must have a concentration equal to the laboratory's lower reporting concentration
for the parameter involved. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total
Residual Chlorine.
Comment: The current calibration curve concentrations are 20, 40, 60, 80 and 100 lag/L. The
current concentration of the daily check standard is 60 lag/L. The last PT sample concentration
true value was 142 lag/L which required a dilution to bring it into the calibration range.
Expanding the verification curve to 400 lag/L will eliminate the need for sample dilution and
lessen the chance of a dilution error.
Recommendation: It is recommended that the laboratory verify the internal calibration using
the concentrations: 20, 30, 50, 200 and 400 lag/L. This will verify the analytical range used to
measure Proficiency Testing (PT) samples as well as environmental samples.
pH — Standard Methods, 4500 H+ B-2000
E. Finding: The laboratory is not analyzing a check buffer after calibrating the pH meter.
Requirement: In addition to the calibration buffers, the meter calibration must be verified with a
third standard buffer solution. Ref: NC WW/GW LC Approved Procedure for the Analysis of pH.
Comment: The analyst thought they were calibrating with two buffers (4 and 10 S.U.) and
checking the calibration with a third buffer (7 S.U.). The analyst did not realize that the meter
required all three buffers for calibration.

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#5123 Town of Snow Hill WWTP
Recommendation: It is recommended that the meter be calibrated with all three buffers.
Reanalyze the 7 S.U. buffer for the calibration check.
F. Finding: The lab is reusing pH buffer portions.
Requirement: Discard any used buffer portions. Ref: NC WW/GW LC Approved Procedure for
the Analysis of pH.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing laboratory benchsheets and contract lab reports to Discharge
Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Resources. Data were
reviewed for June, July and August of 2014. The following error was noted:
Date
Parameter
Location
Value on Benchsheet
Value on DMR
6/9/2014
pH
Effluent
7.4 S.U.
7.1 S.U.
In order to avoid questions of legality, it is recommended that you contact the appropriate Regional
Office for guidance as to whether an amended Discharge Monitoring Report will be required. A copy of
this report will be made available to the Regional Office.
V. CONCLUSIONS:
Correcting the above -cited findings and implementing the recommendations 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.
Report prepared by: Nick Jones Date: November 12, 2014
Report reviewed by: Jason Smith Date: November 17, 2014