#5114_2017_1012_TH_FINAL

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5114
Laboratory Name:
City of Hamlet WWTP
Inspection Type:
Maintenance
Inspector Name(s):
Tom Halvosa and Todd Crawford
Inspection Date:
October 12, 2017
Date Forwarded for Initial
Review:
October 30, 2017
Initial Review by:
Tonja Springer
Date Initial Review
Completed:
October 31, 2017
Cover Letter to use:
❑ Insp. Initial
❑Insp. No Finding
❑Corrected
® Insp. Reg
❑Insp. CP
❑Insp. Reg. Delay
Unit Supervisor/Chemist III:
Todd Crawford
Date Received:
November 6, 2017
Date Forwarded to Admin.:
November 14, 2017
Date Mailed:
November 15, 2017
Special Mailing Instructions:

Water Resources
ENVIRONMENT AL QUALITY
November 15, 2017
5114
Mr. Earl G. Dunn Jr.
City of Hamlet WWTP
P.O. Box 1229
Hamlet, NC 28345
ROY COOPER
MICHEAL S. REGAN
r<<
LINDA CULPEPPER
Lderim i)1r,, r 1
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Dunn:
Enclosed is a report for the inspection performed on October 12, 2017 by Tom Halvosa. 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.
Sincerely,
Todd Crawford
Technical Assistance & Compliance Specialist
NC WW/GW Laboratory Certification Branch
Attachment
cc: Dana Satterwhite, Tom Halvosa, Master File # 5114
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] `, FAX: [phone]
Internet: httD:/idea.nc.goviaboutidivisions/water-resources/water-resources-data/water-sciences-home-page/laboratory-certification-branch

LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
INTRODUCTION:
City of Hamlet WWTP
NC0047562, WQ0002269
790 Freeman Mill Road
Hamlet, NC 28345
5114
October 12, 2017
Field Municipal Maintenance
Tom Halvosa and Todd Crawford
Earl G. Dunn, Jr. and Darrell Lowery
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:
Staff were forthcoming and seemed eager to adopt necessary changes. Laboratory personnel
coordinate sample analyses effectively to manage workload and holding times. 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. The laboratory is commended for having an
Equipment Maintenance Log, which is not required by 15A NCAC 2H .0800.
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 Cameron Testing Services, Inc. (Certification # 654).
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:
Documentation
Comment: The laboratory benchsheet was lacking instrument identification. The NC WW/GW
LC Approved Procedure for the Analysis of Total Residual Chlorine, NC WW/GW LC Approved
Procedure for the Analysis of Dissolved Oxygen and NC WW/GW LC Approved Procedure for the
Analysis of pH documents state: The following must be documented in indelible ink whenever
sample analysis is performed: Instrument Identification and Thermometer/Instrument

Page 2
#5114 City of Hamlet WWTP
Identification. Acceptable corrective action (i.e., the benchsheets were updated to include the
instrument ID, were reprinted and immediately put into use) was performed by the laboratory and
approved by the auditor during the inspection. No further response is necessary for this
Finding.
Comment: The laboratory benchsheet was lacking facility name. The NC WW/GW LC Approved
Procedure for the Analysis of Total Residual Chlorine and NC WW/GW LC Approved Procedure
for the Analysis of Temperature documents state: The following must be documented in indelible
ink whenever sample analysis is performed: Sample site including facility name and location, ID,
etc. Acceptable corrective action (i.e., the benchsheets were updated to include the facility name,
were reprinted and immediately put into use) was performed by the laboratory and approved by
the auditor during the inspection. No further response is necessary for this Finding.
Comment: The laboratory needs to increase the traceability documentation of purchased
materials and reagents. NC WW/GW LC Policy 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 (where specified). 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 primary
standards, chemicals, reagents, and materials used for a period of five years. Consumable
materials such as pH buffers, lots of pre -made standards and/or media, solids and bacteria filters,
etc. are included in this requirement. Acceptable corrective action (i.e., a lab supply receipt log
was printed then filled out and immediately put into use) was performed by the laboratory and
approved by the auditor during the inspection. No further response is necessary for this
Finding.
Comment: The units of measure are not consistently documented on the benchsheets for Total
Residual Chlorine. The North Carolina Administrative Code, 15A NCAC 2H .0805 (g) (1) states:
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. Acceptable corrective action (i.e., the benchsheets were updated to
include the proper units of measure, were reprinted and immediately put into use) was performed
by the laboratory and approved by the auditor during the inspection. No further response is
necessary for this Finding.
A. Finding: Data qualifiers from the contract laboratory reports are not being transferred to
the eDMR.
Requirement: When quality control (QC) failures occur, the laboratory must attempt to
determine the source of the problem and must apply corrective action. Part of the
corrective action is notification to the end user. If data qualifiers are used to qualify
samples not meeting QC requirements, the data may not be useable for the intended
purposes. It is the responsibility of the laboratory to provide the client or end -user of the
data with sufficient information to determine the usability of the qualified data. Where
applicable, a notation must be made on the Discharge Monitoring Report (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.

Page 3
#5114 City of Hamlet VWVFP
Comment: An example of this was from the Cameron Testing BOD report dated
February 9, 2017 where qualifier "A" was not transferred to the eDMR. Qualifier "A"
states: All BOD QC requirements were not met. The dilution water blank was not <0.20
mg/L. Data should be considered valid.
Proficiency Testing
B. Finding: Additional Quality Control (QC) beyond what is routine for Compliance
Samples is being analyzed with PT Samples.
Requirement: Laboratories are required to analyze an appropriate PT Sample by each
parameter method on the laboratory's Certified Parameters Listing (CPL). The same PT
Sample may be analyzed by one or more methods. Laboratories shall conduct the
analyses in accordance with their routine testing, calibration and reporting procedures,
unless otherwise specified in the instructions supplied by the Accredited PT Sample
Provider. This means that they are to be logged in and analyzed using the same staff,
sample tracking systems, standard operating procedures including the same equipment,
reagents, calibration techniques, analytical methods, preparatory techniques (e.g.,
digestions, distillations and extractions) and the same quality control acceptance criteria.
PT Samples shall not be analyzed with additional quality control. They are not to be
replicated beyond what is routine for Compliance Sample analysis. Although, it may be
routine to spike Compliance Samples, it is neither required, nor recommended, for PT
Samples. PT Sample results from multiple analyses (when this is the routine procedure)
must be calculated in the same manner as routine Compliance Samples. Ref:
Proficiency Testing Requirements, May 31, 2017, Revision 2.0.
C. Finding: The preparation of Proficiency Testing (PT) Samples is not documented.
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, May 31, 2017, Revision 2.0.
Comment: Dating and initialing the instruction sheet for the preparation of the Total
Residual Chlorine PT would satisfy the documentation requirement.
Chlorine, Total Residual — Standard Methods, 4500 Cl G-2000 (Aqueous)
D. Finding: Values less than the established reporting limit are being reported on the
electronic Discharge Monitoring Report (eDMR).
Requirement: The concentrations of the calibration standards must bracket the
concentrations of the samples analyzed. One of the standards must have a
concentration equal to or below the lower reporting concentration for Total Residual
Chlorine. The lower reporting limit must be less than or equal to the permit limit. Ref: NC
WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine.
Comment: The lower reporting limit is determined by the concentration of the lowest
standard in the calibration curve verification. The concentration of the lowest standard in

Page 4
#5114 City of Hamlet WVVfP
IV
the laboratory's most recent calibration curve verification was 10 pg/L. Compliance
samples with concentrations less than 10 pg/L must be reported as "<10 pg/L" on the
eDMR.
Dissolved Oxygen — Standard Methods, 4500 O G-2001 (Aqueous)
E. Finding: The laboratory is not performing a post -analysis calibration verification when
analyses are performed away from the certified laboratory's primary location.
Requirement: When performing analyses away from the certified laboratory's primary
location, a post analysis calibration verification must be analyzed at the end of the run. 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. Ref: NC WW/GW LC Approved
Procedure for the Analysis of Dissolved Oxygen.
PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) and contract lab reports to eDMRs submitted to the North Carolina Division of Water
Resources. Data were reviewed for City of Hamlet WWTP (NPDES permit # NC0047562 and
Water Quality permit # WQ0002269). The following error was noted:
Value on
Date
Parameter
Location
Benchsheet
Value on eDMR
8/9/2017
pH
Effluent
7.7
7.4
To avoid questions of legality, it is recommended that you contact the appropriate Regional
Office for guidance as to whether an amended eDMR(s) will be required. A copy of this report
will be made available to the Regional Office.
V. CONCLUSIONS:
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 its assistance during the
inspection and data review process. Please respond to all Findings and include supporting
documentation and implementation dates for each corrective action.
Report prepared by: Tom Halvosa
Report reviewed by: Tonja Springer
Date: October 27, 2017
Date: October 31, 2017

C
a)
E
a
N
9 a)
5 N m Q
Z m Q
a) Q C <0
J
W ' N O
U N
U W w Q
W
F-
LU
IL
d t0
c� m
G OD
N
@ aEi Z
a
O LL
O E
U r- 2
J �
Q O N
0 0
j a)
o N
a) 0
o 0
Q Z Q
Q a
0w
J o O o
o Q
N X N
O 0 0 0
N W O
m h o
V LLj U O
= H m
o o
Z Z LU
o o
i.� 0 It V'
't a N
ZUU)U)U) -
U)wcn