#5053_2019_0611_JMS_FINAL

Laboratory Cert. #:
5053
Laboratory Name:
Town of Mars Hill WWTP
Inspection Type:
Field Municipal Maintenance
Inspector Name(s):
Jason Smith
Inspection Date:
6/11/2019
Date Forwarded for Initial
6/13/2019
Review:
Initial Review by:
Anna Ostendorff
Date Initial Review
6/14/2019
Completed:
❑ Insp. Initial
® Insp. Reg
Cover Letter to use:
❑Insp. No Finding
❑Corrected
❑Insp. CP
❑Insp. Reg. Delay
(to use: rt click, properties, check)
Unit Supervisor/Chemist III:
Todd Crawford
Date Received:
6/24/2019
Date Forwarded to Admin.:
6/24/2019
Date Mailed:
6/25/2019
Special Mailing Instructions:

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5053
Mr. Jason Riddle
Town of Mars Hill WWTP
P.O. Box 368
Mars Hill, NC 28754
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June 25, 2019
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Riddle:
Enclosed is a report for the inspection performed on June 11, 2019 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 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] Ext. 251.
Attachment
cc: Dana Satterwhite, Jason Smith
Sincerely,
Todd Crawford
Technical Assistance & Compliance Specialist
NC WW/GW Laboratory Certification Branch
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North Carolina Department of Environmental Quality I Division of Water Resources
1623 Mail Service Center 1 Raleigh, North Carolina 27699-1623
Phone [phone]/Fax [phone]

LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
L INTRODUCTION:
Town of Mars Hill WWTP
NC0057151 and NC0083712
504 Cascade St
Mars Hill, NC 28754
5053
June 11, 2019
Field Municipal Maintenance
Jason Smith
Jason Riddle
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.
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.
In addition to their own samples, the laboratory analyzes pH and Total Residual Chlorine
samples for the Mars Hill Water Treatment Plant.
All required Proficiency Testing (PT) Samples for the 2019 PT Calendar Year have not yet been
analyzed. The laboratory is reminded that results must be received by this office directly from the
vendor by September 30, 2019.
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
data. It is not intended to imply that existing records are not adequately maintained unless the
Finding speaks directly to that.
Contracted analyses are performed by Earth Environmental Services (Certification # 352).

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#5053 Town of Mars Hill WWTP
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.
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Documentation
A. Finding: Error corrections are not properly performed.
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 Polices for Field Laboratories,
Comment: Error corrections are not dated.
D. Finding: The laboratory needs to increase the traceability documentation of purchased
materials and reagents. This is considered pertinent data.
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: An example log to document this information was provided at the time of the
inspection.
C. Finding: Documentation of the calibration variables for the Dissolved Oxygen (DO) meter
does not include all pertinent data.
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Calibration variables (elevation, temperature, barometric pressure
[in mmHg], salinity). Ref: NC WW/GW LC Approved Procedure for the Analysis of
Dissolved Oxygen.
Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A
NCAC 2H .0805 (g) (1).
Comment: The laboratory documented the calibration by writing "auto". The YSI 550A is
calibrated based on the elevation and salinity, which must be documented.
D. Finding: The laboratory benchsheet is lacking pertinent data: Instrument identification
(serial number preferred).

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#5053 Town of Mars Hill WWTP
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Instrument identification (serial number preferred). Ref: NC
WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine (DPD
Colorimetric), NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen,
NC WW/GW LC Approved Procedure for the Analysis of pH and NC WW/GW LC
Approved Procedure for the Analysis of Temperature.
Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A
NCAC 2H .0805 (g) (1).
Comment: This Finding applies to DO, pH, Temperature and Total Residual Chlorine.
F. Finding: The laboratory benchsheet is lacking pertinent data for Total Residual Chlorine:
True value of the Daily Check Standard(s).
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: True value of the Daily Check Standard(s). Ref: NC WW/GW LC
Approved Procedure for the Analysis of Total Residual Chlorine (DPD Colorimetric).
Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A
NCAC 2H .0805 (g) (1).
F. Finding: The laboratory benchsheets for pH are lacking pertinent data: true values of
buffers used for calibration.
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: true values of buffers used for calibration. Ref: NC WW/GW LC
Approved Procedure for the Analysis of pH.
Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A
NCAC 2H .0805 (g) (1).
Comment: The laboratory is calibrating the pH meter with pH buffers of 4.0 S.U., 7.0 S.0
and 10 S.U. However, the laboratory benchsheet only lists the 4.0 S.U. and 10 S.U.
calibration buffers. All pH buffers used in pH meter calibration must be documented.
Proficiency Testing
G. 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, October 29, 2018, Revision 3.
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.

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#5053 Town of Mars Hill WWTP
H. 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, October 29, 2018, Revision 3.
Comment: Dating and initialing the instruction sheet for the preparation of the Total
Residual Chlorine PT Sample would satisfy the documentation requirement.
I. Finding: The laboratory is not analyzing a Reagent Blank, when applicable.
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 (DPD Colorimetric).
Requirement: The concentration of the reagent blank must not exceed 50% of the
reporting limit (i.e., the lowest calibration or calibration verification standard concentration),
unless otherwise specified by the reference method, or corrective action must be taken.
Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine
(DPD Colorimetric).
J. Finding: The laboratory bases the reporting limit on each permit's Daily Maximum Limit
(<17 pg/L for the WWTP and <28 pg/L for the WTP); however, the lower reporting limit
established by the annual curve verification is 13 pg/L.
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 less than the permitted Daily Maximum 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 (DPD
Colorimetric).
Requirement: Per 15A NCAC 02B .0505 (e) (4), facilities must produce detection and
reporting levels that are below the Daily Maximum Limit. Ref: NC WW/GW LC Approved
Procedure for the Analysis of Total Residual Chlorine (DPD Colorimetric).
Comment: The laboratory currently has established a lower reporting limit of 13 pg/L by
having verified that concentration when verifying the latest calibration curve. Values with
concentrations less than that must be reported as < 13 pg/L on the DMR. Values 13 pg/L
and greater are to be reported as observed.

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#5053 Town of Mars Hill WWTP
Chlorine, Total Residual — Standard Methods, 4500 Cl G-2011 (Aqueous)
Dissolved Oxygen — Standard Methods,10 f (Aqueous)
•Standard Methods, 1 1' (Aqueous)
K. Finding: The laboratory is not analyzing a Post -Analysis Calibration Verification Standard
when analyses are performed at multiple locations for Total Residual Chlorine, Dissolved
Oxygen and pH.
Requirement: When performing analyses at multiple sample sites in a single day, a Post -
Analysis Calibration Verification Standard must be analyzed after the last sample. It is
recommended that a mid -day calibration verification be performed when samples are
analyzed over an extended period of time. The value obtained for the Post -analysis
Calibration Verification Standard must read within 10% of the true value of the Post -
analysis Calibration Verification Standard for standards >_ 50 pg/L and within 25% of its
true value for standards < 50 pg/L. If the obtained value is outside of the acceptance limits,
corrective action must be taken. NC WW/GW LC Approved Procedure for the Analysis of
Total Residual Chlorine (DPD Colorimetric).
Requirement: When performing analyses at multiple sample sites, a Post -Analysis
Calibration Verification Standard must be performed at the end of the run, regardless of
meter type. It is recommended that a mid -day calibration verification be performed when
samples are analyzed over an extended period of time. The calculated DO value must
verify the meter reading within ±0.5 mg/L. If the meter verification does not read within
±0.5 mg/L of the theoretical DO, corrective action must be taken. Alternatively, if the meter
is calibrated at each sample site prior to analysis, a post -analysis calibration verification is
not required. Ref: NC WW/GW LC Approved Procedure for the Analysis of Dissolved
Oxygen.
Requirement: When performing analyses at multiple sample sites, a Post -Analysis
Calibration Verification Standard using the check standard buffer must be analyzed at the
end of the run. It is recommended that a mid -day check standard buffer be analyzed when
samples are analyzed over an extended period of time. The post -analysis check standard
buffer(s) must read within ±0.1 S.U. or corrective actions must be taken. If recalibration is
necessary, all samples analyzed since the last acceptable calibration verification must be
reanalyzed, if possible. If samples cannot be reanalyzed, the data must be qualified. Ref:
NC WW/GW LC Approved Procedure for the Analysis of pH.
Comment: If the meter is recalibrated at each sample location before sample analysis,
Post -Analysis Calibration Verification would not be required.
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) and contract laboratory reports to Discharge Monitoring Reports (DMRs) submitted to the
North Carolina Division of Water Resources. Data were reviewed for the Town of Mars Hill
WWTP (NPDES permit #NC0057151) and the Town of Mars Hill WTP (NPDES permit #
NC0083712) for July, September and December 2018. No transcription errors were observed.
The facility appears to be doing a good job of accurately transcribing data.
With the exception of Total Residual Chlorine, the laboratory does not report undetected analytes
as less than values. It is recommended that the laboratory include the "<" sign when reporting
undetected analytes in order for the monthly average to be properly calculated. The NC DEQ

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#5053 Town of Mars Hill WWTP
document titled Directions for Completing Monthly Discharge Monitoring Reports states: For
calculation purposes only, recorded values of less than a detectable limit (< #.#/#) may be
considered to equal zero (0) for all parameters except Fecal Coliform, for which values of 'less
than" may be considered to be equal to one (1). Values of results which are less than a detectable
limit should be reported in the daily cells using the 'less than" symbol (<) and the detectable limit
used during the testing (or the value with appropriate unit conversion). Please note there is never
a case when an average would need to be recorded along with a 'less than" symbol.
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 Date: June 13, 2019
Report reviewed by: Anna Ostendorff Date: June 14, 2019

North Carolina Wastewater/Groundwater Laboratory Certification
Certified Parameters Listing
Lab Name:
Town of Mars Hill WWTP
Certificate Number:
5053
Address:
504 Cascade St
Effective Date:
1/1/2019
Mars Hill, NC 28754-
Expiration Date:
12/31/2019
Dale of Last Amendment:
10/21/2016
The above named
laboratory, having duly met the requirements of 15A NCAC 2H.0800, is hereby certified for the measurement of the parameters listed below.
_ —
-
_. — __
CERTIFIED PARAMETERS_
INORGANIC
CHLORINE, TOTAL RESIDUAL
SM 4500 Cl G-2011 (Aqueous)
DISSOLVED OXYGEN
SM 4500 O G-2011 (Aqueous)
pH
SM 4500 H+B-2011 (Aqueous)
TEMPERATURE
SM 2550 B-2010 (Aqueous)
71
This certification requires maintance of an acceptable quality assurance program, use of approved methodology, and satisfactory performance on evaluation samples. Laboratories are subject to civil penalties andfor decertification for infractions
as set forth in 15A NCAC 21-1.0807.