#5103_2019_0314_MC_FINAL

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Laboratory Cert. #:
5103
Laboratory Name:
Town of Ramseur WWTP
Inspection Type:
Field Municipal Maintenance
Inspector Name(s):
Michael Cumbus, Beth Swanson
Inspection Date:
March 14, 2019
Date Forwarded for Initial
Review:
March 29, 2019
Initial Review by:
JIVIS
Date Initial Review
Completed:
April 3, 2019
Cover Letter to use:
❑ Insp. Initial ❑ Insp. Reg
❑Insp. No Finding ®Insp. CP
❑Corrected
(to use: click, prcpo io , check)❑Insp. Reg. Delay
Unit Supervisor/Chemist II:
Beth Swanson
Date Received:
April 3, 2019
Date Forwarded to Admin.:
April 11, 2019
Date Mailed:
April 11, 2019
Special Mailing Instructions:
Michael email copy to Lon Snider - WSRO

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April 11, 2019
5103
Mr. Terry Lewallen
Town of Ramseur WWTP
P.O. Box 217
Ramseur, NC 27316-
SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Lewallen:
Enclosed is a report for the inspection performed on March 14, 2019 by Michael Cumbus and Beth
Swanson. 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 findings were
corrected and include an implementation date for each corrective action.
We are concerned with the findings that were cited previously and not 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 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] ext. 259.
Sincerely,
9AL----
Beth Swanson
Technical Assistance & Compliance Specialist
Division of Water Resources
Attachment cc: Michael Cumbus, Dana Satterwhite, Lon Snider
North Carolina Department of Environmental Quality I Division of Water Resources
1623 Mail Service Center I Raleigh, North Carolina 27699-1623
Phone [phone]/Fax [phone]

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Town of Ramseur WWTP
NC0026565
4735 Roundleaf Rd.
Ramseur, NC 27316
5103
March 14, 2019
Field Municipal Maintenance
Michael Cumbus and Beth Swanson
LOCAL PERSON(S) CONTACTED: Terry Lewallen
INTRODUCTION:
This laboratory was inspected by representatives 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.
GENERAL COMMENTS:
The laboratory was neat and has all the equipment necessary to perform the analyses. Staff was
forthcoming and responded well to suggestions from the auditors.
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 Environment 1, Inc. (Certification # 10) and Meritech, Inc.
(Certification #165).

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#5103 Town of Ramseur 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.
Documentation
A. Finding: Error corrections are not always 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.
D. Finding: The laboratory benchsheets are lacking pertinent data: permit number, method
reference.
Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A
NCAC 2H .0805 (g) (1).
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: permit number, method reference. Ref: NC WW/GW LC Approved
Procedure for the Analysis of pH, 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 (DO) and NC WW/GW LC Approved Procedure for the
Analysis of Temperature.
Comment: The laboratory benchsheets reference outdated methods. The method
references must be updated to reflect the current version as listed on the laboratory's
Certified Parameters Listing (CPL).
C. Finding: The laboratory needs to document traceability information of purchased materials
and reagents. This is considered pertinent data.
Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A
NCAC 2H .0805 (g) (1).
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.
Proficiency Testing
D. 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

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#5103 Town of Ramseur WWTP
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.
E. Finding: The laboratory is not documenting PT Sample analyses in the same manner as
routine Compliance Samples. Cited previously on December 15, 2011.
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.
Comment: The laboratory was recording the results directly onto the reporting form for the
PT samples.
F. Finding: When the low-level Mercury Field Blank is outside of QC criteria, the laboratory
does not include the Field Flank data or qualification on the Discharge Monitoring Report
(DMR).
Requirement: If a field blank fails to meet quality control criteria, the permittee should note
that fact in the DMR Comments Section, and append the lab sheet for that field blank. Ref:
NCDEQ [formerly NCDENR DWQ] Memo, NPDES Mercury Requirement — EPA Method
1631 Additional Information, August 12, 2003.
Requirement: Where applicable, a notation must be made on the DMR form, in the
comment section, when any required sample quality control does not meet specified criteria
and another sample cannot be obtained. Ref: Quality Assurance Policies for Field
Laboratories.
Comment: The laboratory is reporting Low Level Mercury results from the contract
laboratory on the DMRs, but is not reporting the value for the associated Field Blank, nor
qualifying data when Mercury is detected in the Field Blank outside of QC limits.
Comment: The NPDES Mercury Requirement memo can be found on the NC WW/GW LC
website at htto f/ o ,nc.g of b t/divi ions/water-resources/grater-resources-data/ ater-
sciences-hon - e/f i�or for ceitff!c t or-br nch/?p roved-n�,ethod -info. _
Sampling
G. Finding: The laboratory is not resampling if the low-level Mercury Field Blanks are outside
QC criteria.

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#5103 Town of Ramseur WWTP
Requirement: For those facilities sampling for mercury under a limited monitoring
frequency (quarterly or less, such as Pretreatment LTMP/STMP monitoring), you must
resample if the field blanks are outside quality control criteria. Ref: NCDEQ DWQ Memo,
NPDES Mercury Requirement — EPA Method 1631 Additional Information, August 12,
2003.
Comment: Per EPA method 1631 E, the low-level Mercury Field Blanks are considered
outside QC criteria if the concentration is equal to or greater than the lowest calibration
standard [which is equivalent to the laboratory's reporting limit], or greater than one -fifth the
level in the associated sample, whichever is greater. It is the permittee's responsibility to
compare the reported result for Field Blanks with the laboratory's reporting limit or the level
in the associated sample and qualify the associated sample results on the DMR when the
Field Blank is outside quality control criteria and subsequently resample.
pH — Standard Methods, 4500 H+ B-2011 (Aqueous)
H. Finding: The pH meter is not calibrated prior to analysis of samples each day compliance
monitoring is performed.
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. The calibration
and check standard buffers must bracket the range of the samples being analyzed. Ref: NC
WW/GW LC Approved Procedure for the Analysis of pH.
Recommendation: It is recommended that the laboratory perform a post -analysis
calibration verification using the check standard buffer at the end of the run when samples
are analyzed over an extended period of time.
Temperature — Standard Methods, 2550 B-2010 (Aqueous)
Finding: The thermometer calibration verification documentation does not include the
stated accuracy or the expiration date of the National Institute of Standards and Technology
(NIST) traceable temperature -measuring device that was used in the comparison. This is
considered pertinent data.
Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A
NCAC 2H .0805 (g) (1).
Requirement: All compliance temperature -measuring devices without a valid NIST
certificate must be checked initially and every 12 months against an NIST traceable
temperature -measuring device and the process documented. Documentation must include
the serial number of the device being checked. The serial number, stated accuracy and
expiration date of the NIST traceable temperature -measuring device used in the
comparison must also be documented. Verification data must be kept on file and be
available for inspection for 5 years. (NOTE: Vendors or other Certified laboratories may
provide assistance in meeting this requirement. When a vendor or other Certified laboratory
provides this assistance they must provide a copy of their NIST Certificate or the serial
number, accuracy and calibration expiration date.) Ref: NC WW/GW LC Approved
Procedure for the Analysis of Temperature.

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#5103 Town of Ramseur WWTP
Chlorine, Total Residual — Standard Methods, 4500 Cl G-2011 (Aqueous)
J. Finding: The three gel -type standard values used to obtain the true value are not
documented.
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 DPD Colorimetric Analysis of Total Residual
Chlorine.
Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A
NCAC 2H .0805 (g) (1).
Comment: The laboratory is contracting the gel -type standard verification to Meritech, Inc.
Meritech informed the auditor that the gel -standard "new true value" was indeed based on
the average of three readings but was unable to provide the raw data upon request.
Meritech was informed that this information needed to be documented and that they
needed to include this information in the reports to their clients.
Dissolved Oxygen — Standard Methods, 4500 O G-2011 (Aqueous)
K. Finding: The laboratory is not performing a post -analysis calibration verification when
analyses are performed at multiple sample sites.
Requirement: When performing analyses at multiple sample sites, a post -analysis
calibration verification 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.
Comment: The laboratory may recalibrate the meter at each site before sample analysis to
avoid this requirement.
L. Finding: The meter is not being calibrated according to the manufacturer's instructions.
Requirement: Instruments are to be calibrated according to the manufacturer's calibration
procedure prior to analysis of samples each day compliance monitoring is performed. Ref:
NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen.
Requirement: Before calibration or measurement for dissolved oxygen, the probe must be
polarized and the settings for atmospheric pressure and salinity must be entered. Ref:
HACH senslON + Portable Meter Operator's Manual.
Comment: The factory -set atmospheric pressure is being used for each calibration. The
laboratory may find the current atmospheric pressure at:
tpt ps1NL t, �EL_ ov/data/'g i.istor '�1j Y ht k in the upper right corner under the
heading sea level (mb).
Comment: Once the laboratory begins inputting the atmospheric pressure into the meter,
the pressure must be documented on the spreadsheet each day.

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#5103 Town of Ramseur WWTP
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 Town of Ramseur WWTP
(NPDES permit # NC0026565) for January 2019 and June, September and December 2018.
The following errors were noted:
Value on
Benchsheet
Date
Parameter
Location
Value on DMR
*Contract Lab
Data
1/1/2019
Total Residual
Effluent
3 pg/L
**< 15 pg/L
Chlorine
1/15/2019
Total Residual
Effluent
2 pg/L
**< 15 pg/L
Chlorine
12/18/2018
Mercury
Effluent
*1.9 n /L
0.0019 n /L
12/18/2018
Mercury
Field
Blank
*6.7 ng/L
No Value Reported
9/25/2018
Mercury
Effluent
*<1 ng/L
0.001 n /L
9/25/2018
Mercury
Field
Blank
*3.7 ng/L
No Value Reported
6/12/2018
Mercury
Effluent
*<1 n /L
< 0.001 n /L
6/12/2018
Mercury
Field
Blank
*1.2 ng/L
No Value Reported
** The Laboratory's reporting limit is currently 10 pg/L based on the most recent calibration curve
verification.
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:
We are concerned with the Finding that was cited previously and not corrected.
Laboratory Decertification Ref: 15A NCAC 2H .0807 (a) (1), (13) and (14):
A laboratory may be decertified for any or all parameters for up to one year for any or all of the
following infractions:
(1) Failing to maintain the facilities, or records, or personnel, or equipment, or quality control
program as set forth in the application, and these Rules; or
(13) Failing to respond to requests for information by the date due; or

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#5103 Town of Ramseur VVVVTP
(14) Failing to comply with any other terms, conditions, or requirements of this Section or of a
Laboratory certification.
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: Michael Cumbus Date: March 29, 2019
Report reviewed by: Jason Smith Date: April 3, 201

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