#5270_2019_0314_MC_FINAL

Laboratory Cert. #:
5270
Laboratory Name:
Town of Ramseur WTP
Inspection Type:
Field Municipal Maintenance
Inspector Name(s):
Beth Swanson, Michael Cumbus
Inspection Date:
March 14, 2019
Date Forwarded for Initial
Review:
March 25, 2019
Initial Review by:
Tonja Springer
Date Initial Review
Completed:
March 26, 2019
Cover Letter to use:
❑ Insp. Initial ® Insp. Reg
❑Insp. No Finding ❑Insp. CP
❑Corrected ❑Insp. Reg. Delay
Unit Supervisor/Chemist II:
Beth Swanson
Date Received:
March 28, 2019
Date Forwarded to Admin.:
April 11, 2019
Date Mailed:
April 11, 2019
Special Mailing Instructions:
Michael email copy to Lon Snider at WSRO

ROYCOOPER
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April 11, 2019
5270
Mr. Mark Grose
Town of Ramseur WTP
797 Hwy 22 North
Ramseur, NC 27316-
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Grose:
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 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. 259.
Sincerely,
Ali
Beth Swanson
Technical Assistance & Compliance Specialist
Division of Water Resources
Attachment
cc: Michael Cumbus, Dana Satterwhite, Lon Snider WSRO
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]

CERTIFICATE #:
LOCAL PERSON(S) CONTACTED:
R";N111•
Town of Ramseur WTP
NCG590019
797 Highway 22 North
Ramseur, NC 27316
5270
March 14, 2019
Field Municipal Maintenance
Beth Swanson and Michael Cumbus
Mark Grose
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 appeared neat and organized. The facility had all the equipment necessary to
perform the analyses. Staff was friendly and embraced recommendations made by the auditors.
Records were easily accessible and organized.
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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#5270 Town of Ramseur VVTP
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.
- - • 13 vagemm z I g •
General Laboratory
A. Finding: The laboratory does not report results of all tests on the characteristics of the
effluent.
Requirement: 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. Ref: 15A NCAC 213.0506 (b) (3) (J).
Comment: The laboratory requested the October 2, 2018 effluent be analyzed for Sulfate
by Environment 1, Inc. but did not report it on the Discharge Monitoring Report (DMR) for
that month. The Paper Trail in Section IV of this report contains specifics regarding the data
in question.
Documentation
B. Finding: The laboratory benchsheets are lacking pertinent data: instrument identification
(serial number preferred).
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 pH.
Requirement: Data pertinent to each analysis must be maintained for five years. Ref:
15A NCAC 2H .0805 (g) (1).
Comment: The laboratory uses two different pH probes on the same meter, designated as
Probe #1 and Probe #2 . The serial number is preferred, though "Probe 1" and "Probe 2"
would be considered acceptable, provided that these designations were recorded in the
laboratory's consumables log with each new probe that is put into use.
Recommendation: It is recommended that the laboratory incrementally increase the
"Probe Number" for each new probe that is utilized so each probe identifier is associated
with only one serial number.
C. Finding: The laboratory benchsheets are lacking pertinent data: permit number.
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: permit number. 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 pH.
Requirement: Data pertinent to each analysis must be maintained for five years. Ref:
15A NCAC 2H .0805 (g) (1).
D. Finding: The laboratory benchsheets are lacking pertinent data: units of measure, date of
most recent calibration curve verification, percent recovery of the daily calibration check
standard.

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#5270 Town of Ramseur WfP
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: units of measure as specified in the permit, date of most recent
calibration curve verification, percent recovery of the daily calibration check standard. 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.
Certified data must consist of date collected, time collected, samples 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).
Comment: The laboratory instrument calibration log for Total Residual Chlorine (TRC) is
lacking units of measure.
Comment: The laboratory benchsheet for TRC is lacking the date of the most recent
calibration curve verification.
Comment: The laboratory is not documenting the percent recovery of the daily calibration
check standard to demonstrate the analytical process is in control and the established
acceptance criterion is being met.
E. 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.
F. Finding: The laboratory benchsheets reference unapproved methods and/or do not fully
reference the approved methods.
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: 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).
Requirement: Laboratory procedures, analytical methods, sample preservation, sample
containers and sample holding times shall conform to those requirements found in 40 CFR-
136.3. Ref: 15A NCAC 2H .0805 (a) (1).
Comment: The laboratory benchsheets for pH and TRC reference outdated methods. The
benchsheets must be updated to reflect the methods as listed on the Certified Parameters
Listing (CPL).
G. Finding: All original records are not being maintained for five years.

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#5270 Town of Ramseur WTP
Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A
NCAC 2H .0805 (g) (1).
Comment: The results of analyses are originally written on a piece of paper and
transferred to the operator's computer spreadsheet. This original paperwork is then
discarded.
H. 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. 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. 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).
Requirement: Chemicals must be dated when received and when opened. Ref: 15A
NCAC 2H .0805 (a) (7) (L).
Comment: Expiration dates and lot numbers were pre -entered in the laboratory
benchsheet and not updated as needed to reflect the buffers and reagents currently in use.
Date Opened (in use) was not documented in a permanent record or on the reagent
container.
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.
J. 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 (DPD
Colorimetric).

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#5270 Town of Ramseur WTP
Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A
NCAC 2H .0805 (9) (1).
Comment: The laboratory is contracting the gel -type standard verification to Meritech, Inc.
This office notified Meritech of the requirement to document the three individual readings of
the gel -type standards as well as report the average of three readings.
Proficiency T�
K. 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.
Comment: The laboratory was recording results on the PT reporting sheet, not on the
laboratory benchsheet.
L. 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 9, 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.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) and contract erb reports to e reviewed forMRs Townof Ramtted seurto the North WTP (NC Generalllina Per Division
#
Resources. Data w NCG590019)
for January, May and October 2018. The following errors were noted:
Value on Benchsheet Value on DMR
Date Parameter Location *Contract Lab Data
10/02/2018 Fluoride Effluent *0.19 m /L **19 /L
10/02/2018 Sulfate Effluent *113 m /L No value re orted
**The value on the DMR should have been entered as 190 pg/L

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#5270 Town of Ramseur WTP
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.
Correcting the above -cited Findings and implementing the Recommendation 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 25, 2019
Report reviewed by: Tonja Springer Date: March 26, 2019

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