#5364_2017_0928_AO_FINAL

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5364
Laboratory Name:
Town of Severn WWTP
Inspection Type:
Field Municipal Maintenance
Inspector Name(s):
Anna Ostendorff
Inspection Date:
September 28, 2017
Date Forwarded for Initial
November 2, 2017
Review:
Initial Review by:
Jason Smith
Date Initial Review
November 2, 2017
Completed:
❑ Insp. Initial
❑ Insp. Reg
Cover Letter to use:
❑Insp. No Finding
❑Corrected
❑Insp. CP
®Insp. Reg. Delay
(to use: rt click, properties, check)
Unit Supervisor/Chemist III:
Dana Satterwhite
Date Received:
November 3, 2017
Date Forwarded to Admin.:
November 14, 2017
Date Mailed:
November 15, 2017
Special Mailing Instructions:
Anna — send copy to RRO regarding Finding G.

W aterResources
ENVIRONMENTAL. QUALITY
November 15, 2017
5364
Mr. M.E. Lassiter
Town of Severn WWTP
P.O. Box 401
Severn, NC 27877
ROY COOPER
MICHEAL S. REGAN
LINDA CULPEPPER
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Lassiter:
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Enclosed is a report for the inspection performed on September 28, 2017 by Anna Ostendorff. I
apologize for the delay in getting this report to you, 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].
Sincerely,
Dana Satterwhite, Environmental Program Supervisor
Division of Water Resources
Attachment
cc: Anna Ostendorff, Master File #5364
Water Sciences Section
NC WastewateriGroundwater Laboratory Certification Branch
1623 Mail Service Center, Raleigh, North Carolina 27699-1623
Locaticn: 4405 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone]V FAX: [phone]
Internet: http://deQ.nc.gov/aboutid!visions/water-resourcestwater-resources•data/water-sciences-home- age/labo€atory.certification-branch

LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
I. INTRODUCTION:
Town of Severn WWTP
WQ0001868
314 Main Street
Severn, NC 27877
5364
September 28, 2017
Field Municipal Maintenance
Anna Ostendorff
Marshall Lassiter and Troy Holloman
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 were receptive to adopting the necessary changes in response to the
inspection. The laboratory regularly collaborates with neighboring municipalities on issues
pertaining to laboratory certification and wastewater testing and analysis to the benefit of
everyone.
All required Proficiency Testing (PT) Samples have been analyzed for the 2017 PT Calendar Year
and the graded results were 100% acceptable.
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).
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:

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#5364 Town of Severn VWVfP
Proficiency Testing
A. Finding: The laboratory is not documenting PT Sample analyses in the same manner
as routine Compliance Samples.
Requirement: As specified in 15 NCAC 2H .0800, in order to meet the minimum
standards for Certification, laboratories must use acceptable analytical methods. The
acceptable methods are those defined or referenced in the current State and federal
regulations for the environmental matrix being tested. All samples, (including PT
Samples) that are, or that may, be used for Certification purposes, must be analyzed
using approved methods only. 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 analysis of PT Samples is designed to evaluate the entire process used
to routinely report environmental analytical results; therefore, PT Samples must be
analyzed and the process documented in the same manner as Compliance Samples.
Documentation
B. Finding: The laboratory needs to increase the traceability documentation of purchased
materials and reagents.
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. This information 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).
Comment: An example traceability log was provided by the auditor during the
inspection and may be used to fulfill this requirement.
C. Finding: The analyst is not signing or initialing laboratory benchsheets indicating who
collected and analyzed the sample.
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).
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Collector's/analyst's name or initials. Ref: NC WW/GW LC
Approved Procedure for the Analysis of pH and NC WW/GW LC Approved Procedure
for the Analysis of Temperature.

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#5364 Town of Severn WWTP
D. Finding: The laboratory benchsheet was lacking pertinent data: Instrument
identification. This is considered pertinent data.
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).
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Instrument identification. Ref: NC WW/GW LC Approved
Procedure for the Analysis of pH and NC WW/GW LC Approved Procedure for the
Analysis of Temperature.
E. Finding: The units of measure for pH (i.e., Standard Units or S.U.) are not documented
on the benchsheets.
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).
F. Finding: The pH calibration check standard was not recorded to one decimal point.
Requirement: Use a pH meter accurate and reproducible to 0.1 pH unit (as
demonstrated daily by acceptable performance of a check standard buffer) with a range
of 0 to 14 and equipped with temperature -compensation adjustment. The meter must be
calibrated with at least two buffers. In addition to the calibration buffers, the meter
calibration must be verified with a third standard buffer solution. The calibration and
check standard buffers must bracket the range of the samples being analyzed. 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. Ref: NC WW/GW LC Approved Procedure for the Analysis of
pH.
Comment: The analyst travels to several monitoring wells and performs the analysis on
site. The pH meter calibration is checked with a 7.0 S.U. buffer after each analysis and
before traveling to the next location. The documented value of the check standard does
not include any decimal values and is recorded as 7. The analyst is aware the check
standard must measure within 0.1 S.U. of the true value. However, it cannot be
determined from the records if the check buffer measured within the required range of
6.9 to 7.1 S.U.
pH — Standard Methods, 4500 H+ B-2000 (Aqueous)
G. Finding: The laboratory was reporting non -compliant data for pH on the Non -Discharge
Monitoring Report (NDMR).
Requirement: Analyze within 15 minutes. Ref: Code of Federal Regulations, Title 40,
Part 136; Federal Register Vol. 82, No. 165, August 28, 2017; Table 11.

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#5364 Town of Severn WWTP
Comment: The laboratory was analyzing pH on -site, but reporting the pH value
provided by the contract laboratory on the NDMR, which has a statement that the value
is "not to be used for reporting". The hold time for pH was not met for the analyses
performed by the contract laboratory. The laboratory must use the value from the on -site
analysis for reporting purposes.
Recommendation: To avoid questions of legality, it is recommended that you contact
the appropriate Regional Office for guidance as to whether an amended eDMR(s)/
DMR(s) will be required. A copy of this report will be made available to the Regional
Office.
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 Severn WWTP (Water Quality permit #
WQ0001868) for November and August 2016 and February 2017. No transcription errors were
observed. The facility appears to be doing a good job of accurately transcribing data.
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 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: Anna Ostendorff Date: November 2, 2017
Report reviewed by: Jason Smith Date: November 2, 2017

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