#5466_2020_0226_JMS_FINAL

Laboratory Cert. #:
5466
Laboratory Name:
Hickory Regional Compost Facility
Date Mailed:
1144
Special Mailing Instructions:
Send VAR: Option 5 Approved Procedure with the report.

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
5466
Mr. Paul Spencer
Hickory Regional Compost,Facility
3200 20th Avenue SE
Newton, NC 28658
NORTH CAROLINA
Environmental Quality
May 4, 2020
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW
LC) Maintenance Inspection
Dear Mr. Spencer:
Enclosed is a report for the inspection performed on February 26, 2020 by Jason Smith. 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] Ext. 259.
Sincerely,
Todd Crawford
Technical Assistance & Compliance Specialist
Division of Water Resources
Attachment
cc: Jason Smith, Dana Satterwhite
North Carolina Department of Environmental Quality I Division of Water Resources
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4405 Reedy Creel: Road 1 1623 Mail Service Center I Raleigh, North Carolina 27699-1623
NORTH cARouNA '`
Department of EMI—nmul..� 919.733.3908

Hickory Regional Compost Facility
WQOOO4563
3200 20'h Avenue SE
Newton, NC 28658
,A.
February 27, 2020
Field Maintenance
Jason Smith
LOCAL PERSON(S) CONTACTED: Paul Spencer and Logan Hughes
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 compliance monitoring samples.
Ill. GENERAL COMMENTS:
All required Proficiency Testing (PT) Samples for the 2020 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, 2020.
The laboratory is reminded that Standard Operating Procedure (SOP) documents are required to
be implemented by July 1, 2020. SOP templates may be found on the NC WW/GW LC website
here: https://deg.nc.gov/about/divisions/water-resources/water-resources-data/water-sciences-
home-page/laboratory-certification-branch/technical-assistance-policies Additionally, a
documented training program for current and future analysts must be implemented by August 1,
2020. These requirements and the SOP templates posted on the NC WW/GW LC website were
discussed during the inspection. Any time changes are made to laboratory procedures, the
laboratory must update the SOP document(s) and inform relevant staff. In some instances, the
laboratory may need to create an SOP to document how new functions or policies will be
implemented.
The laboratory is also reminded that SOPs are intended to describe procedures exactly as they
are to be performed. Use of the word "should" is not appropriate when describing requirements
(e.g., Quality Control (QC) frequency, acceptance criteria, etc.). Evaluate all SOPs for the proper
use of the word "should".

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#5466 Hickory Regional Compost Facility
Contracted analyses are performed by Pace Analytical Services LLC -- Asheville, NC (Certification
# 40).
General Laboratory
A. Finding: The laboratory is analyzing samples and reporting data [pH by SM 4500 H+ 13-
2011 (Aqueous) and Vector Attraction Reduction: Option 5 — Aerobic Treatment Above 40
°C (Non -aqueous)] without North Carolina Wastewater/Groundwater Laboratory
Certification.
Requirement: Municipal and Industrial laboratories shall obtain Certification for Field
Parameter Methods used to generate data that will be reported to the State in accordance
with the rules of this Section. Ref: 15A NCAC 02H .0804 (a).
D. Finding: The laboratory does not report all characteristics of the pollutants analyzed from
permitted locations.
Requirement: If the permittee monitors any pollutant at the location(s) designated herein
more frequently than required by this permit, using approved analytical methods as
specified above, the results of such monitoring shall be submitted to the Control Authority
and/or Municipality. Ref: City of Hickory Industrial User Pretreatment (IUP) Permit, IUP
Number 50, Part II, (4).
Requirement: Monitoring results obtained by the permittee shall be reported on forms
specified by the Control Authority and/or Municipality. Ref: City of Hickory Industrial User
Pretreatment (IUP) Permit, IUP Number 50, Part II; (2) (a).
Comment: The Pretreatment Log includes effluent data from the permitted location
analyzed in excess of the required frequency. A copy of the Pretreatment Log is sent to
Hickory Public Works, but the results are not reported on the Industrial Discharge
Monitoring Report (IDMR).
Recommendation: It is recommended that if the facility analyzes samples for
parameters not required in the permit or in excess of the required frequency, the samples
be taken upstream of the permit specified effluent location. This would allow for process
control to continue and the results would not be required to be reported. It is also
recommended that flow only be documented at the frequency required in the permit.
Documentation
C. Finding: Uncertified data is not documented as such on the benchsheets.
Requirement: Data Reporting. Each certified Field Laboratory shall be in accordance with
Paragraph (e) of this Rule. Ref: 15A NCAC 02H .0805 (g) (17).
Requirement: All Uncertified Data shall be documented as such on the benchsheet and
on the final report. Ref: 15A NCAC 02H .0805 (e) (3).

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#5466 Hickory Regional Compost Facility
Comment: The Pretreatment Log includes pH, Settleability, Dissolved Oxygen and
Ammonia Nitrogen data that must be documented as Uncertified Data because the
laboratory is not certified for these parameters and/or the procedures are not approved.
D. Finding: Error corrections are not always properly performed.
Requirement: All documentation errors shall 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; instead the correction shall be written
adjacent to the error. The correction shall be initialed by the responsible individual and the
date of change documented. Ref: 15A NCAC 02H .0805 (g) (1).
Comment: Some instances of overwriting and multiple lines through errors were
observed.
E. Finding: The laboratory benchsheet is lacking required documentation: the method or
Standard Operating Procedure.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses and shall consist of: the method or
Standard Operating Procedure. Each item shall be recorded each time samples are
analyzed. Analyses shall conform to methodologies found in Subparagraph (a)(1) of this
Rule. Ref: 15A NCAC 021-1.0805 (g) (2) (A).
Comment: This Finding applies to all parameters.
F. Finding: The laboratory benchsheet is lacking required documentation: the instrument
identification.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses "and shall consist of: the instrument
identification. Each item shall be recorded each time samples are analyzed. Ref: 15A
NCAC 02H .0805 (g) (2) (C).
Comment: This Finding applies to all parameters.
G. Finding: The laboratory benchsheet is lacking required documentation: permit number.
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Facility name, sample site (ID or location), and permit number. Ref:
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 VAR Option 5.
Comment: This Finding applies to pH by SM 4500 H+ B-2011 (Aqueous), Temperature by
SM 2550 B-2010 (Aqueous) and VAR: Option 5.
H. Finding: The laboratory benchsheet is lacking required documentation: sample
identification.

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#5466 Hickory Regional Compost Facility
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall' be traceable to the associated sample analyses and shall consist of: sample
identification. Each item shall be recorded each time samples are analyzed. Ref: 15A
NCAC 02H .0805 (g) (2) (1).
Comment: This Finding applies to pretreatment samples analyzed for pH by SM 4500 Id'
B-2011 (Aqueous) and Temperature by SM 2550 8-2010 (Aqueous).
Finding: The laboratory benchsheet is lacking required documentation: time of sample
collection.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses and shall consist of: the date and
time of sample collection. Each item shall be recorded each time samples are analyzed.
Ref; 15A NCAC 02H .0805 (g) (2) (F).
Comment: This Finding applies to pH by SM 4500 H+ B-2011 (Aqueous).
J. Finding: The laboratory benchsheet is lacking required documentation: time of sample
analyses.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses and shall consist of: the time of
sample analyses (when required to document a required holding time or when time -critical
steps are imposed by the method, a federal regulation, or this Rule). Each item shall be
recorded each time samples are analyzed. Ref: 15A NCAC 02H .0805 (g) (2) (H).
Comment: This Finding applies to pH by SM 4500 H+ B-2011 (Aqueous).
K. Finding: The laboratory benchsheet is lacking required documentation: the proper units of
measure.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses and shall consist of: the proper units
of measure. Each item shall be recorded each time samples are analyzed. Ref: 15A
NCAC 02H .0805 (g) (2) (L).
Comment: This Finding applies to Temperature by SM 2550 8-2010 (Aqueous).
Recommendation: It is recommended that all benchsheets and calibration logs be
reviewed and have units of measure added where missing. Other than aqueous
Temperature analyses, units of measure are documented in hand-held notebooks where
data is originally recorded, but not on all benchsheets and logs where the data is
transcribed.
L. Finding: The laboratory benchsheet is lacking required documentation: the signature or
initials of the analyst.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses and shall consist of: the signature or
initials of the analyst. Each item shall be recorded each time samples are analyzed. Ref:
15A NCAC 02H .0805 (g) (2) (E).

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#5466 Hickory Regional Compost Facility
Comment: This Finding applies to pretreatment samples analyzed for Temperature by SM
2550 B-2010.
Proficiency Testlng
M. 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, February 19, 2020, Revision 5, Section 3.6.
Requirement: The laboratory shall retain all records necessary to facilitate historical
reconstruction of the analysis and reporting of analytical results for PT Samples. This
means the laboratory must have available and retain for five years [pursuant to 15A NCAC
02H .0805 (a) (7) (E) and (g) (1)] all of the raw data, including benchsheets, instrument
printouts and calibration data, for all PT Sample analyses and the associated QC analyses
conducted by all parameter methods. Ref: Proficiency Testing Requirements, February 19,
2020, Revision 5, Section 4.0.
Temperature — SM 2550 B-2010 (Aqueous)
Vector Attraction Reduction: Option 5 — Aerobic Treatment Above 40deg C
N. Finding: The Reference Temperature -Measuring Device used for verifying compliance
and compost temperature -measuring devices is in 1 °C increments.
Requirement: A Reference Temperature -Measuring Device is an NIST traceable
temperature -measuring device used only to verify the calibration of other temperature -
measuring devices. It must have a stated accuracy of ± 0.5 °C, be able to distinguish
temperature changes of 0.1 °C and equilibrate rapidly. Ref: NC WW/GW LC Approved
Procedure for the Analysis of Temperature and NC WW/GW LC Approved Procedure for
the Analysis of VAR Option 5.
Comment: Increments of 1 °C are not adequate to distinguish temperature changes of
0.1 °C.
Temperature — SM 2550 B-2010 (Aqueous)
O. Finding: The compliance temperature -measuring device verification procedure is not
performed correctly.
Requirement: To check a compliance temperature -measuring device, compare readings
at two temperatures that bracket the range of compliance samples routinely analyzed
against a Reference Temperature -Measuring Device and record all four readings. The
readings from both devices must agree within 0.5 °C. If they do not, the device may not be
used for temperature compliance monitoring. Ref: NC WW/GW LC Approved Procedure
for the Analysis of Temperature.
Comment: The temperature -measuring devices are compared to a Reference
Temperature -Measuring Device at one temperature. The temperature -measuring device
for aqueous sample analyses is checked without adjusting the tap water temperature.

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#5466 Hickory Regional Compost Facility
VA
Vector Attraction Reduction: Option 5 7 Aerobic Treatment Above 40 deg C
P. Finding: The temperature -measuring device is not able to distinguish temperature
changes of 0.1 'C.
Requirement: All compost temperature measurements must be made with an NIST
traceable temperature -measuring device with a demonstrated accuracy of ± 0.5 °C that is
able to distinguish temperature changes of 0.1 'C and equilibrate rapidly. Ref: NC
WW/GW LC Approved Procedure for the Analysis of VAR: Option 5.
Comment: The thermometer is graduated
thermometer in use by the laboratory offers
fulfill this requirement.
in 1 °C increments. The manufacturer of the
a digital version that would be acceptable to
No paper trail performed. VAR: Option 5 data is compiled into an annual report and reviewed by
the Mooresville Regional Office. Pretreatment data is reviewed by Henry Fork WWTP.
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: Jason Smith
Report reviewed by: Tonja Springer
Date: April 13, 2020
Date: April 13, 2020

NORTH CAROLINA WASTEWATER/GROUNDWATER LABORATORY CERTIFICATION
APPROVED PROCEDURE FOR THE ANALYSIS OF VECTOR ATTRACTION REDUCTION
(VAR): OPTION 5
Aerobic Processes at Greater Than 40 °C [503.33(b)(5)]
This document provides an approved procedure for the analysis of VAR: Option 5 for compliance monitoring per
15A NCAC 2H .0805 (a) (7) and (g) (4).
Not Applicable — sample temperature is measured in -situ.
® Option 5 must be used for composted aerobically -treated sewage sludge.
® Option 5 may also be applied to sewage sludge from other aerobic processes such as aerobic digestion
as long as temperature requirements can be met and the sewage sludge is maintained in an aerobic state
for the treatment period; however, Options 3 and 4 are likely to be easier to meet for these type sewage
sludges.
® All compost temperature measurements must be made with a National Institute of Standards and Technology
(NIST) traceable temperature -measuring device with a demonstrated accuracy of t 0.5 °C that is able to
distinguish temperature changes of 0.1 °C and equilibrate rapidly. Traceability to NIST may be established by
comparison with a Reference Temperature -Measuring Device as described below.
® Infrared (IR) devices are not acceptable for compost temperature measurements.
® All temperature -measuring devices must be immersed in the sample to the proper depth as specified by the
manufacturer. Partial immersion thermometers are designed with scales calibrated to indicate the true
temperature when the thermometers are immersed to specified depths. Total immersion thermometers are
designed with the scales calibrated to indicate the true temperature when the bulb and the portion of liquid
column, to just above the temperature being read, is exposed to the sample being measured. If a total
immersion thermometer is used as a partial immersion thermometer, an emergent stem correction must be
performed. NOTE: Probe type thermometers will also have a specified immersion depth. Refer to the
manufacturer's manual for the proper immersion depth.
THERMOMETER CALIBRATION:
® A Reference Temperature -Measuring Device is an NIST traceable temperature -measuring device used only
to verify the calibration of other temperature -measuring devices. It must have a stated accuracy of t 0.5 °C,
be able to distinguish temperature changes of 0.1 °C and equilibrate rapidly.
® When temperature -measuring devices with their own valid NIST traceable certificate are used to measure
compost temperatures, initial verification is not required. However, they must be verified against a
Reference Temperature -Measuring Device and the process documented at the proper frequency (i.e.,
every 3 months for digital devices and every 12 months for all other types) after the date of first use or
certificate expiration, whichever comes first.
® Non -digital compost temperature -measuring devices without an NIST certificate, or with an expired NIST
certificate, must be verified against a Reference Temperature -Measuring Device and the process
documented initially and every 12 months thereafter (or sooner if the temperature -measuring device has
been exposed to temperatures beyond the manufacturer's recommended range of use or other stresses).
® Digital compost temperature -measuring devices without an NIST certificate, or with an expired NIST
certificate, must be verified against a Reference Temperature -Measuring Device and the process
documented initially and at least every 3 months thereafter (or sooner if the temperature -measuring device
has been exposed to temperatures beyond the manufacturer's recommended range of use or other
stresses).
Rev. 05/01 /2020

® To check a compost temperature -measuring device, compare a reading at the temperature of use (i.e., 40 t
0.5 °C) against a Reference Temperature -Measuring Device and record the two readings. The readings from
both devices must agree within 0.6 °C. If they do not, the device may not be used
® Verification documentation must include the serial number of the device being checked and the serial
number, stated accuracy and expiration date of the Reference Temperature -Measuring Device used in the
comparison. 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.)
g
Check and document the temperature of the compost at representative locations within the pile each day of a 14-
day period using a calibrated temperature -measuring device. Each day the temperature must be over 40 °C (104
°F).
At the end of the 14-day period calculate and document the average temperature over the 14 days. The average
temperature must be greater than 45 °C (113 °F).
Because the entire mass of sewage sludge must attain the required temperatures for the required duration, the
temperature profiles from every monitoring point, not just the average of the points, must be over 40 °C (104 °F)
and the average temperature must be greater than 45 °C (113 'F).
It has been found that points within 0.3 m (1 foot) of the surface of aerated static piles may be unable to reach
these temperatures, and for this reason, it is recommended that a 0.3 m (1 foot) or greater layer of insulating
material be placed over all surfaces of the pile. Finished compost is often used for insulation. It must be noted that
because the insulation will most likely be mixed into the composted material during post -processing or curing,
compost used as an insulation material must be a Class A material so as not to reintroduce pathogens into the
composting sewage sludge. Regardless of whether an insulating layer is used, temperature measurements must
be performed within 0.3 m (1 foot) of the surface of the unfinished compost.
DOCUMENTATION:
The following must be documented in indelible ink whenever sample analysis is performed:
I. Facility name, sample site (ID or location), and permit number
2. Collector's/analyst's name or initials
3. Parameter analyzed
4. Method reference or Standard Operating Procedure
5. Dates analyzed
6. Sample temperature measurements for each day in the specified units
'C=(°F-32)/1.8
°F=(°CX1.8)+32
7. 14-day average temperature at each sample location
8. Thermometer/instrument identification (serial number preferred)
9. Units of measure
10. Data qualifiers, when necessary
11. Equipment maintenance (recommended)
Refer to http://deg.nc.gov/about/divisions/water-resources/water-resources-data/water-sciences-horne-
page/laboratory-certification-branch/technical-assistance-policies) for additional quality assurance and quality control
requirements.
This document was prepared using Control of Pathogens and Vector Attraction in Sewage Sludge, EPA/625/R-
92/013, (July 2003) as a reference.
Rev. 05/01 /2020

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