#5251_2017_0308_TS_FINAL

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5251
Laboratory Name:
Town of Robbins WWTP
Inspection Type:
Field Municipal Maintenance
Inspector Name(s):
Tonja Springer
Inspection Date:
March 8, 2017
Date Forwarded for Initial
Review:
April 6, 2017
Initial Review by:
Anna Ostendorff
Date Initial Review
Completed:
April 7, 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:
April 11, 2017
Date Forwarded to Admin.:
May 3, 2017
Date Mailed:
May 5, 2017
Special Mailing Instructions:

Water Resourres
May 5, 2017
5251
Mr. Tommy Gibbons
Town of Robbins WWTP
P.O. Box 296
Robbins, NC 27325
MICHEAL S. REGAN
S. JAI' ZIMMERMAN
SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Gibbons:
Enclosed is a report for the inspection performed on March 8, 2017 by Tonja Springer. Since the
Finding(s) cited during the inspection were all corrected prior to the completion of the enclosed report, a
response is not required. The staff is commended for taking the initiative in correcting the Findings in
such a timely manner. 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 electronic mail, 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, Tonja Springer, Master File 5251

LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
I. INTRODUCTION:
Town of Robbins WWTP
NC0062855
256 Bear Ridge Road
Robbins, NC 27325
5251
March 8, 2017
Field Municipal Maintenance
Tonja Springer
Tommy Gibbons
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 facility has all the equipment necessary to perform the analyses. The laboratory analyst was
very forthcoming and receptive to implementing the necessary changes in response to the
Findings and Recommendations made during the inspection.
All required Proficiency Testing (PT) samples for the 2017 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, 2017.
Contracted analyses are performed by Pace Analytical Services LLC - Raleigh NC (Certification #
67).
Current 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 pertinent data: instrument identification. The
NC WW/GW LC Approved Procedure for the Analysis of Temperature, NC WW/GW LC
Approved Procedure for the Analysis of pH, NC WW/GW LC Approved Procedure for the
Analysis of Dissolved Oxygen and NC WW/GW LC Approved Procedure for the Analysis of Total
Residual Chlorine documents state: The following must be documented in indelible ink whenever
sample analysis is performed: Instrument identification. Notification of acceptable corrective action

#5251 Town of Robbins WWTP
(i.e., an updated benchsheet which includes instrument identification with an implementation date
of March 17, 2017) was received by email on April 5, 2017. No further response is necessary
for this Finding.
Comment: Date Received, Date Opened (in use), Vendor, Lot Number and Expiration Dates
are not being documented for pH buffers and Total Residual Chlorine (TRC) DPD powder
reagents. The NC WW/GW LC Quality Assurance Policies for Field Laboratories document
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. Notification of acceptable corrective action (i.e., an updated benchsheet that
included the documentation of the date received, date opened, vendor, lot number and expiration
dates with an implementation date of March 17, 2017) was received by email on March 17, 2017.
No further response is necessary for this Finding.
Proficiencv Testin
Comment: The laboratory is not analyzing PT samples in the same manner as compliance
samples. The laboratory's common practice was to analyze a known standard along with the PT
sample as additional QC. Since this is not performed with all compliance samples, it is
considered additional QC. However, known samples are recommended when analyzing
remedial PT samples as part of the troubleshooting and corrective action process. The
Proficiency Testing Requirements, February 20, 2012, Revision 1.2. document states: 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 and any other samples analyzed
according to the requirements of 15A NCAC 2H .0800. Notification of acceptable corrective
action (i.e., a statement that beginning with the 2017 PTs, a known standard will not be
analyzed with the unknown PT sample) was received by email on March 16, 2017. No further
response is necessary for this Finding.
Comment: The preparation of TRC PT samples is not documented._ The TRC vendor
preparation instructions are being kept on file but they are not initialed and dated. The
Proficiency Testing Requirements, February 20, 2012, Revision 1.2. document states: PT
samples received as ampules must be diluted according to the PT provider's instructions. The
preparation of PT samples must be documented in a traceable log or other traceable format.
The diluted PT sample becomes a routine environmental sample and is added to a routine
sample batch for analysis. Notification of acceptable corrective action (i.e., a statement that
beginning with the 2017 PT samples the PT vendor's preparation instructions will be initialed
and dated and kept as a permanent record for five years) was received by email on April 5,
2017. No further response is necessary for this Finding.
Comment: The laboratory is not documenting TRC and pH PT sample analyses in the same
manner as environmental samples. PT sample results are documented directly on the vendor
report form and not on the benchsheet. The Proficiency Testing Requirements, February 20,
2012, Revision 1.2. document states: All PT sample analyses must be recorded in the daily
analysis records as for any environmental sample. This serves as the permanent laboratory
record. Notification of acceptable corrective action (i.e., a statement that beginning in 2017, all
PT samples will be documented in the same manner as environmental samples on the
benchsheet) was received by email on March 16, 2017. No further response is necessary for
this Finding.

#5251 Town of Robbins WWTP
Dissolved OMen — Hach 10360-2011, Rev. 1.2 (LDO) (Aqueous)
Comment: The laboratory is using a Luminescent Dissolved Oxygen (LDO) probe, but was not
aware that NC WW/GW LC program grants Certification for this technology based upon Hach
Method 10360 or ASTM Method D 888-09 C. Standard Methods 4500 O G-2000 is specifically for
analysis by membrane electrode. The laboratory's Certified Parameter Listing (CPL) was
amended with an effective date of April 5, 2017 with Hach Method 10360 added and SM 4500 O
G-2000 deleted.
pH — Standard Methods, 4500 H+ B-2000 (Aqueous)
Comment: The check standard buffer is not analyzed after calibration and prior to sample
analysis. The 7.0 S.U. check standard buffer is being analyzed after samples are analyzed. The
NC WW/GW LC Approved Procedure for the Analysis of pH document states: The check
standard buffer must read within ±0.1 S.U. to be acceptable. If the meter verification does not
read within ±0.1 S.U., the meter must be recalibrated before any samples are analyzed.
Notification of acceptable corrective action (i.e., a statement that the check buffer will be
analyzed after calibration and prior to sample analysis with an implementation date of March 9,
2017) was received by email on March 16, 2017. No further response is necessary for this
Finding.
Comment: Values were reported that exceed the method specified accuracy of 0.1 units.
Standards Methods, 4500 H+ B-2000. (6) states: By careful use of a laboratory pH meter with
good electrodes, a precision of ±0.02 unit and an accuracy of ±0.05 unit can be achieved.
However, ± 0.1 pH unit represents the limit of accuracy under normal conditions, especially for
measurement of water and poorly buffered solutions. For this reason, report pH values to the
nearest 0.1 pH unit. Notification of acceptable corrective action (i.e., a statement that pH
results are now being reported on the eDMR to the nearest 0.1 pH units with an implementation
date of March 17, 2017 and changes on the eDMR will be effective on the next eDMR submittal
before March 30, 2017) was received by email on March 16, 2017. No further response is
necessary for this Finding.
Comment: The laboratory benchsheet was lacking pertinent data: units of measure. The NC
WW/GW LC Approved Procedure for the Analysis of pH document states: The following must
be documented in indelible ink whenever sample analysis is performed: Units of measure.
Notification of acceptable corrective action (i.e., an updated benchsheet that included units of
measure with an implementation date of March 9, 2017) was received by email on March 16,
2017. No further response is necessary for this Finding.
IV. 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 Town of Robbins WWTP (NPDES # NC0062855) for
February and December 2016. The following errors were noted:

#5251 Town of Robbins VWVfP
Value on Benchsheet
Date
Parameter
Location
Value on eDMR
*Contract Lab Data
2/17/2016
BOD
Influent
*39.9 mg/L
23.1 mg/L
2/17/2016
TSS
Influent
*23.1 mg/L
39.9 mg/L
To avoid questions of legality, it is recommended that you contact the appropriate Regional Office
for guidance as to whether an amended eDMR will be required. A copy of this report will be made
available to the Regional Office.
V. CONCLUSIONS:
All Findings noted during the inspection were adequately addressed prior to the completion of
this report. The inspector would like to thank the staff for its assistance during the inspection and
data review process. No response is required.
Report prepared by: Tonja Springer Date: April 5, 2017
Report reviewed by: Anna Ostendorff Date: April 7, 2017

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