#5671_2018_0524_MC_FINAL

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To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5671
Laboratory Name:
West Stanly WWTP
Inspection Type:
Field Municipal Initial
Inspector Name(s):
Michael Cumbus, Beth Swanson
Inspection Date:
May 24, 2018
Date Forwarded for Initial
Review:
June 1, 2018
Initial Review by:
Jason Smith
Date Initial Review
Completed:
June 4, 2018
Cover Letter to use:
® Insp. Initial
❑Insp. No Finding
❑Corrected
❑ Insp. Reg
❑Insp. CP
❑Insp. Reg. Delay
Unit Supervisor/Chemist III:
Beth Swanson
Date Received:
June 7, 2018
Date Forwarded to Admin.:
June 12, 2018
Date Mailed:
June 12, 2018
Special Mailing Instructions:
Michael- send to Wes Bell @ [e-mail]

June 12, 2018
5671
Mr. Donald Zufall
West Stanly WWTP
1000 North First St., Ste. 12
Albemarle, NC 28001
ROY COOPER
f,'ovcr-nor
MICHAEL S. REGAN
s'z�;�ercrr�v
LINDA CULPEPPER
hrierim l?!re ,tor
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Initial
Inspection
Dear Mr. Zufall:
Enclosed is a report for the inspection performed on May 24, 2018 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,
9�
Beth Swanson
Technical Assistance & Compliance Specialist
Division of Water Resources
Attachment
cc: Michael Cumbus, Dana Satterwhite
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] i FAX: [phone]
Internet: http://deg.nc.gov/about/divisions/water-resources/water-resources-datalwater-sciences-home.page/laboratorycertification-branch

LABORATORY NAME:
NPDES PERMIT :
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
I. INTRODUCTION:
West Stanly WWTP
NC0043532
24939-B Barbees Grove Rd
Oakboro, NC 28129
5671
May 24, 2018
Field Municipal Initial
Michael Cumbus and Beth Swanson
Donald Zufall
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 environmental samples.
IL GENERAL COMMENTS:
The facility is neat and well organized and has all the equipment necessary to perform the
analyses. The work area was clean and appeared well maintained. Records are well organized
and easy to retrieve. Staff were forthcoming and seemed eager to adopt necessary changes.
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.

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#5671 West Stanly WWTP
All required Proficiency Testing (PT) Samples for the 2018 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, 2018.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
Recommendation: The laboratory is analyzing and reporting temperature to one decimal place. It
is recommended that the laboratory document temperature to one decimal place on the bench
sheet and round to whole numbers for reporting purposes.
A. 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.
Comment: The laboratory was writing over some data. Some instances where errors had a
single line through them but were not dated or initialed were noted.
B. Finding: The laboratory benchsheet was lacking pertinent data: date and time of sample
analysis, method reference, permit number, instrument identification and units of measure,
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: date and time of sample analysis, method reference, permit number
and instrument identification (serial number preferred). Ref: NC WW/GW LC Approved
Procedure for the Analysis of pH, NC WW/GW LC Approved Procedure for the Analysis of
Dissolved Oxygen, NC WW/GW LC Approved Procedure for the Analysis of Temperature
and NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine.
Comment: Both sample collection and analysis times are documented for pH and Total
Residual Chlorine. However, the laboratory is documenting only one time for sample
collection and analysis for Dissolved Oxygen (DO) and Temperature. It would be
acceptable to note wherever the data is first recorded that these analyses are performed in
situ.
C. Finding: The laboratory benchsheet was lacking pertinent data: true value for the daily
check standard.
Requirement: Data pertinent to each analysis must be maintained for five years. Certified
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).

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#5671 West Stanly WWTP
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: true value for the daily check standard. Ref: NC WW/GW LC
Approved Procedure for the Analysis of Total Residual Chlorine
D. Finding: The preparation of standards and reagents are not documented in such a way as
to provide traceability from preparation to analysis.
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.
E. Finding: Documentation of the DO meter calibration does not include all pertinent data:
calibration variables.
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Calibration variables (elevation, temperature, barometric pressure [in
mmHg], salinity). Ref: NC WW/GW LC Approved Procedure for the Analysis of Dissolved
Oxygen.
Comment: The laboratory is calibrating with elevation and temperature. The elevation of
the laboratory has been programmed into the meter. This may be added to the bench sheet
as a blanket statement.
F. Finding: The compliance temperature -measuring device calibration verification was not
documented. This is considered pertinent data.
Requirement: All compliance temperature -measuring devices without a valid National
Institute of Standards and Technology (NIST) certificate must be checked initially and every
12 months against an NIST traceable temperature -measuring device and the process
documented. Documentation must include the serial number of the device being checked.
The serial number, stated accuracy and expiration date of the NIST traceable temperature -
measuring device used in the comparison must also be documented. Verification data must
be kept on file and be available for inspection for 5 years. (NOTE: Vendors or other
Certified laboratories may provide assistance in meeting this requirement. When a vendor
or other Certified laboratory provides this assistance, they must provide a copy of their
NIST Certificate or the serial number, accuracy and calibration expiration date.) Ref: NC
WW/GW LC Approved Procedure for the Analysis of Temperature.
Comment: The laboratory was checking the temperature sensor on the DO meter against
an NIST traceable thermometer quarterly. A sticker with the verification date was applied to
the meter; however, no data could be produced.

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#5671 West Stanly WWTP
Comment: The laboratory had recently hired new personnel since the last time PT Sample
analysis had been performed. The laboratory must ensure that incoming new personnel enter into
the rotation for PT samples.
G. 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, May 31, 2017, Revision 2.0.
H. 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, May 31, 2017, Revision 2.0.
Comment: Dating and initialing the instruction sheet for the preparation of the Total
Residual Chlorine PT Sample would satisfy the documentation requirement.
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.
Chlorine, Total Residual — Standard Methods, 4500 Cl G-2011 (Aqueous)
Recommendation: The laboratory is using serological pipettes to prepare standards and PT
Samples. It is recommended that the laboratory use volumetric pipettes for critical measurements.
J. Finding: The laboratory is not verifying the instrument's factory -set calibration curve every
12 months.
Requirement: Annual Factory -set Calibration Curve Verification: This type of calibration
curve verification must be performed initially, at least every 12 months and any time the
instrument optics are serviced. Zero the instrument with a Calibration Blank and then

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*5671 West Stanly WWTP
analyze a Reagent Blank and a series of five standards (do not use gel or sealed liquid
standards for this purpose). The calibration standard values obtained must not vary by
more than 10% from the known value for standard concentrations greater than or equal to
50 pg/L and must not vary by more than 25% from the known value for standard
concentrations less than 50 pg/L. Ref: NC WW/GW LC Approved Procedure for the
Analysis of Total Residual Chlorine.
Comment: The laboratory had failed to perform the factory -set curve verification in 2016.
However, documentation was provided for the verification performed in 2017.
K. Finding: The laboratory is not verifying the gel -type standard concentration every 12
months.
Requirement: Purchased "gel -type" or sealed liquid standards may be used only for daily
calibration curve verifications. These standards must have a true value assigned initially
and with each subsequent calibration curve generation/verification thereafter. When this is
done, these standards may be used after the manufacturer's expiration date. Ref: NC
WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine.
Comment: The laboratory had failed to perform the verification of the gel -type standards in
2016. Documentation was provided for the verification performed in 2017.
Comment: The Approved Procedure for the Analysis of Total Residual Chlorine document
was updated in 2018. The laboratory was informed that it is now required to average a
minimum of three values to obtain the new assigned value for the gel standard.
L. Finding: Values less than the established reporting limit are being reported on the
Discharge Monitoring Report (DMR)
Requirement: For all calibration options, the range of standard concentrations must
bracket the permitted discharge limit concentration, the range of sample concentrations to
be analyzed and anticipated PT Sample concentrations. One of the standards must have a
concentration equal to or less than the permitted discharge limit. The lower reporting limit
concentration is equal to the lowest standard concentration. Sample concentrations that are
less than the lower reporting limit must be reported as a less -than value. Ref: NC WW/GW
LC Approved Procedure for the Analysis of Total Residual Chlorine.
Comment: The concentration of the lowest standard analyzed for the annual factory -set
calibration curve verification was 20 pg/L. However, the laboratory is reporting actual
numbers below this value on the DMR. The laboratory must report any value less than the
lowest standard concentration as < 20 pg/L.
Temperature — Standard Methods, 2550 B-2010 (Aqueous)
M. Finding: The calibration of the NIST traceable thermometer used to check other
thermometers and/or temperature sensors had expired.
Requirement: All NIST traceable temperature -measuring devices must have a stated
accuracy of at least ± 0.5°C and be within their expiration date. Ref: NC WW/GW LC
Approved Procedure for the Analysis of Temperature.
Comment: The laboratory sent their reference thermometer to K&W Laboratories
(Certification #559) to be checked on January 19, 2015. However, this was determined to

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#5671 West Stanly WWTP
be a verification and not a recalibration, since this laboratory cannot issue a new NIST
certificate of traceability.
N. Finding: The laboratory is not performing the annual temperature -measuring device check
properly.
Requirement: To check a compliance temperature -measuring device, compare readings
at two temperatures that bracket the range of compliance samples routinely analyzed
against a National Institute of Standards and Technology (NISI) traceable temperature -
measuring device and record all four readings. The readings from both devices must agree
within 0.5 °C. Ref: NC WW/GW LC Approved Procedure for the Analysis of Temperature.
Dissolved Oxygen — Standard Methods, 4500 O G-2011 (Aqueous)
O. Finding: The meter is not being calibrated according to the manufacturer's instructions.
Requirement: Calibration In % Saturation: Ensure that the sponge inside the instrument's
calibration chamber is moist. Insert the probe into the calibration chamber. Ref: YSI 550A
Operator's Manual.
Comment: The laboratory was calibrating in a BOD bottle completely filled with water as
mg/L of a known solution. However, the true value of the water was not known. The
laboratory was instructed to begin calibrating in % Saturation.
pH — Standard Methods, 4500 H+B-2011 (Aqueous)
P. Finding: Values were reported that exceed the method specified accuracy of 0.1 units.
Requirement: 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. Ref: Standard Methods, 4500 H+ B-2011. (6).
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) and contract lab reports to DMRs submitted to the North Carolina Division of Water
Resources. Data were reviewed for West Stanly WWTP (NPDES permit #NC0043532) for
August and October 2017 and March 2018. 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 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
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: June 1, 2018
Report reviewed by: Jason Smith Date: June 4, 2018

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