#5230_2018_0207_AO_FINAL

To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5230
Laboratory Name:
Town of Conway WWTP
Inspection Type:
Field Municipal Maintenance
Inspector Name(s):
Anna Ostendorff
Inspection Date:
February 7, 2018
Date Forwarded for Initial
February 20, 2018
Review:
Initial Review by:
Jason Smith
Date Initial Review
February 20, 2018
Completed:
❑ Insp. Initial
® Insp. Reg
Cover Letter to use:
❑Insp. No Finding
❑Corrected
❑Insp. CP
❑Insp. Reg. Delay
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Unit Supervisor/Chemist III:
Beth Swanson
Date Received:
February 21, 2018
Date Forwarded to Admin.:
February 26, 2018
Date Mailed:
February 27, 2018
Special Mailing Instructions:
Send a copy to the RO and follow-up with a telephone call.

February 27, 2018
5230
Mr. Joey Barnes
Town of Conway WWTP
P.O. Box 365
Conway, NC 27820
ROY COOPER
Go c rnm
MICHAEL S. REGAN
LINDA CULPEPPER
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Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Barnes:
Enclosed is a report for the inspection performed on February 7, 2018 by Anna Ostendorff. 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,
Beth Swanson
Technical Assistance and Compliance Specialist
Division of Water Resources
Attachment
cc: Dana Satterwhite, Anna Ostendorff
Water Sciences Section
NC VVastewater/Groundwater Laboratory Certification Branch
1623 Mail Service Center, Raleigh, North Carolina 27699-1623
Location: 4405 Reedy Creek Road, Raleigh, North Carolina 27607
Phone. [phone] FAX: [phone]
Internet: http://deq.nc.gov/about/divisions/water-resources/water-resources-data/water-sciences-home-pagellaboratory-certification-branch

. MIMMMUMML • • 1
Town of Conway WWTP
WQ0001284
520 Phillips Hill Rd
Conway, NC 27820
5230
February 7, 2018
Field Municipal Maintenance
Anna Ostendorff
LOCAL PERSON(S) CONTACTED: Joey Barnes
I. 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 laboratory has all the equipment necessary to perform the analyses. The benchsheet is well
designed, easy to follow and concise.
The laboratory requested Temperature be removed from the Certified Parameter Listing (CPL)
during the inspection. Temperature is not on the Town of Conway WWTP permit (WQ0001284)
and is not reported on the Non -Discharge Monitoring Report (NDMR). Temperature was
removed from the facility's CPL with an effective date of February 19, 2018.
All required Proficiency Testing (PT) Samples have been analyzed for the 2017 PT Calendar Year
and the graded results were 100% acceptable.
Contracted analyses are performed by Environment 1, Inc. (Certification # 10).
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.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
General Laboratory
A. Finding: The laboratory is reporting data for Total Residual Chlorine (TRC) without NC
WW/GW Laboratory Certification.

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#5230 Town of Conway WWTP
Requirement: Commercial, Municipal, Industrial and Other facilities are required to obtain
certification for field parameters which will be reported by the client to comply with State
surface water, groundwater, and pretreatment Rules. Ref: 15A NCAC 2H .0804 (a).
Comment: Prior to March 2017, the laboratory was not adding chlorine to their effluent nor
analyzing any samples, but was entering a value of "zero" on the NDMR. From March
2017 through August 2017, the laboratory began chlorinating the effluent in response to a
Compliance Evaluation by the Water Quality Regional Operations Section, but did not
begin analyzing samples for TRC, and continued to report "zero" on the NDMR. Since
August 2017, no values have been reported for TRC on the NDMRs although the facility is
still chlorinating.
Comment: The laboratory is reminded that all analyses for compliance monitoring must
be performed by a certified laboratory. Any results from analyses performed without
certification must be reported as uncertified. All the necessary information on how to
become certified for TRC was provided on January 16, 2018,
B. Finding: Chemicals are sometimes used beyond the expiration date.
Requirement: Adherence to manufacturer expiration dates is required. Chemicals,
reagents, standards, consumables exceeding the expiration date can no longer be
considered reliable. If the expiration is only listed as a month and year (with no specific
day of the month), the last day of the month will be considered the actual date of
expiration. Monitor materials for changes in appearance or consistency. Any changes
may indicate potential contamination and the item should be discarded even if the
expiration date is not exceeded. If no expiration date is given, the laboratory must have
a policy for assigning an expiration date. If no date received or expiration date can be
determined, the item should be discarded. Ref: Quality Assurance Policies for Field
Laboratories.
Comment: The 10.0 S.U. pH buffer expired January 2018.
Documentation
Comment: The laboratory documents pH buffer information directly on the benchsheet. However,
if certification for TRC is obtained, the system of traceability will need to be updated to include the
TRC reagents.
Recommendation: The laboratory documents the manufacturer and model of the pH pen -style
meter used for compliance monitoring. It is now recommended that the serial number be used as
the instrument identification, especially since the meter is discarded and replaced each year.
C. 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.

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#5230 Town of Conway WWTP
Comment: Documentation error corrections were made with a strike through and the
correct entry made adjacent to the error, but did not include initials or date of the
correction. Several instances of write overs were also observed.
Proficiency Testing
Comment: It is required that any sample preparation required for PT Sample analysis be
documented. This will be applicable to the TRC PT if certification is obtained. The laboratory
may sign and date a copy of the vendor's preparation instructions to fulfil this requirement. No
documentation is needed for whole volume PT Samples which require no preparation (e.g.,
pH).
D. Finding: The laboratory is not documenting PT Sample analyses in the same manner
as routine Compliance Samples.
Requirement: All PT Samples are to be analyzed and the results reported in a manner
consistent with the routine analysis and reporting requirements of Compliance Samples.
Laboratories must document any exceptions. 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, May 31, 2017,
Revision 2.0.
Comment: The laboratory currently documents the PT Sample results on the report
form provided by the vendor, but not on a benchsheet. The analysis of PT Samples is
designed to evaluate the entire process used to routinely report Compliance Sample
results; therefore, PT Samples must be analyzed and the process documented in the
same manner as Compliance Samples,
E. Finding: PT Samples have not been distributed among all analysts from year to year.
Requirement: Laboratories shall also ensure that, from year to year, PT Samples are
equally distributed among personnel trained and qualified for the relevant tests and
instrumentation (when more than one instrument is used for routine Compliance Sample
analyses), that represents the routine operation of the work group at the time the PT
Sample analysis is conducted. Ref: Proficiency Testing Requirements, May 31, 2017,
Revision 2.0.
pH — Standard Methods, 4500 H+ B-2011 (Aqueous)
Comment: It is now required that a post -analysis calibration check be analyzed after analyzing
pH samples at multiple locations. This is a new requirement effective December 2017 and will
be required when the monitoring wells are next sampled.
F. Finding: The laboratory is not always analyzing a check standard buffer after calibration
and prior to sample analysis.
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
Ref: NC WW/GW LC Approved Procedure for the Analysis of pH.

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#5230 Town of Conway WWTP
Requirement: All check standard buffers must read within ±0.1 S.U. to be acceptable. If
the meter verification does not read within ±0.1 S.U., corrective actions must be taken
before any samples are analyzed. Ref: NC WW/GW LC Approved Procedure for the
Analysis of pH.
Comment: Possible corrective actions may be found in the NC WW/GW LC Approved
Procedure for the Analysis of pH document provided at the time of the inspection.
Comment: The benchsheet has spaces for documenting a two -point calibration using
the 4.0 S.U. and 10.0 S.U. buffers and a space for documenting the 7.0 S.U. check
buffer reading. However, the supervisor indicated that some analysts may be calibrating
with the 7.0 S.U. buffer rather than using it to check the calibration and documenting the
reading. It was discussed during the inspection that the benchsheet could be revised to
provide spaces for a 3-point calibration and a calibration check to eliminate confusion in
the future. Please submit a copy of the revised benchsheet with the inspection
report reply.
Comment: The laboratory is reminded that the supervisor shall provide personal and
direct supervision of the technical personnel and be held responsible for the proper
performance and reporting of all analyses. This includes ensuring all analysts adhere to
the requirements for maintaining accreditation with the NC WW/GW Laboratory
Certification program.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) and contract lab reports to NDMRs submitted to the North Carolina Division of Water
Resources. Data were reviewed for the Town of Conway WWTP (Non -Discharge permit #
WQ0001284) for January, April and August 2017. The following error was noted:
Date
Parameter
Location
Value on
Value on NDMR
Benchsheet
Every day
Total Residual
5/2009 — 8/2017
Chlorine
Effluent
No data
0 mg/L
Reporting values on the NDMR without performing an analysis is considered falsification of data.
North Carolina Administrative Code, 15A NCAC 02H .0803 (6) states: Falsified data or information
means data or information which has been made untrue by alteration, fabrication, omission,
substitution or mischaracterization. To avoid questions of legality, it is recommended that you
contact the appropriate Regional Office for guidance as to whether amended NDMRs will be
required for the months where TRC values of "zero" were reported. 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
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

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#5230 Town of Conway WWTP
respond to all Findings and include supporting documentation, implementation dates
and steps taken to prevent recurrence for each corrective action.
Report prepared by: Anna Ostendorff Date: February 20, 2018
Report reviewed by: Jason Smith Date: February 20, 2018

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