#5388_2016_0720_AO_FINAL

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #: 5388
Laboratory Name: Town of Littleton
Inspection Type: Field Maintenance
Inspector Name(s): Anna Ostendorff, Gary Francies
Inspection Date: July 20, 2016
Date Report Completed: August 16, 2016
Date Forwarded to Reviewer: August 19, 2016
Reviewed by: Tonia Springer
Date Review Completed: August 25, 2016
Cover Letter to use: ❑ Insp. Initial ® Insp. Reg.
❑ Insp. No Finding ❑ Insp. CP
❑ Corrected ❑ Insp. Reg. Delay
Unit Supervisor/Chemist III: Gary Francies
Date Received: August 30, 2016
Date Forwarded to Admin: 9/1/16
Date Mailed: 9/6/2016
Special Mailing Instructions:

Water Resources
ENVIRONMEN 1 A(_ QUA Lti TY
September 1, 2016
5388
Mr. Harold K. Hamm
Town of Littleton
PO Box 87
Littleton, NC 27850
PAT MCCRORY
DONALD R. VAN DER VAART
,' if.
S. JAY ZIMMERMAN
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Hamm:
Enclosed is a report for the inspection performed on July 20, 2016 by Anna Ostendorff and Gary
Francies. 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.
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,
Gary Francies, Technical Assistance/Compliance Specialist
Division of Water Resources
Attachment
cc: Anna Ostendorff
master file
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: http:11deg.nc.gov/about/divisions/water-resou rceslwater-resources-datalwater-sciences-home-pageliaborate ry-certification- bran ch

On -Site Inspection Report
LABORATORY NAME: Town of Littleton
NPDES PERMIT #: NCO025691
ADDRESS: 501 NC Highway 4
Littleton, NC 27850
CERTIFICATE #: 5388
DATE OF INSPECTION: July 20, 2016
TYPE OF INSPECTION: Field Municipal Maintenance
AUDITOR(S): Anna Ostendorff and Gary Francies
LOCAL PERSON(S) CONTACTED: Keith Hamm
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 environmental samples.
GENERAL COMMENTS:
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. Records are well
organized and easy to retrieve. Staff were forthcoming and seemed eager to adopt necessary
changes.
All required Proficiency Testing (PT) samples for the 2016 PT calendar year have not yet been
analyzed. The laboratory is reminded that results must be received by the office directly from the
vendor by September 30, 2016.
Contracted analyses are performed by Microbac Laboratories, Inc. (Certification # 11).
Current Quality Assurance Policies for Field Laboratories and Approved Procedure documents for
the analysis of the facility's currently certified methods were provided at the time of the inspection.
The facility was certified for Total Residual Chlorine (TRC) by SM 4500 Cl D-2000 but analyzing
samples by using Hach method 10014. The Certified Parameter List has been corrected since the
inspection to reflect the current practice.
III. FINDINGS REQUIREMENTS COMMENTS AND RECOMMENDATIONS:
Documentation
Comment: The laboratory needs to increase the documentation of purchased materials and
reagents. The 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.

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5388 Town of Littleton
This information must be retained for a period of five years. Consumable materials such as pH
buffers and lots of pre -made standards are included in this requirement. Notification of acceptable
corrective action (i.e., a statement that the traceability form provided by the auditor will be used
with an effective date of July 25, 2016) was received by email July 29, 2016. No further
response is necessary for this Finding.
Quality Control
Comment: The laboratory is not calibrating auto-pipettors annually. The Quality Assurance
Policies for Field Laboratories document states: Mechanical volumetric liquid -dispensing devices
(e.g., fixed and adjustable auto-pipettors, bottle -top dispenser, etc.), used for critical
measurements, must be calibrated at least every twelve months and documented. Each liquid -
dispensing device must meet the manufacturer's statement of accuracy. For variable volume
devices used at more than one setting, check the accuracy at the maximum, middle and minimum
values. Testing at more than three volumes is optional. When a device capable of variable
settings is dedicated to dispense a single specific volume, calibration is required at that setting
only. Notification of acceptable corrective action (i.e., a statement that volumetric pipets will be
used for critical measurements with an effective date of July 26, 2016) was received by email July
29, 2016. No further response is necessary for this Finding.
Proficiency Testing
Comment: The preparation of Proficiency Testing (PT) samples is not documented. 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 the
practice of signing, dating and retaining the vendor's preparation instructions will be
implemented with the 2016 PT sample analyses) was received by email July 29, 2016. No.
further response is necessary for this Finding.
Comment: The laboratory was not documenting PT sample analyses in the same manner as
environmental samples. 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 the practice of documenting PT sample
analyses on a benchsheet will be implemented with the 2016 PT sample analyses) was received
by email July 29, 2016.
Comment: The laboratory was not analyzing PT samples in the same manner as compliance
samples. Known standards were analyzed along with the PT sample as additional quality control.
Since this is not performed with all compliance samples, it is considered additional quality control.
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 all QC samples will be analyzed at least one day prior to the PT
samples and will be implemented with the 2016 PT sample analyses) was received by email July
29, 2016.
Dissolved Oxygen — Standard Methods, 4500 O G-2001 (Aqueous)
Conductivity —Standard Methods, 2510 B-1997 (Aqueous)

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5388 Town of Littleton
Comment: All original records were not on file for upstream and downstream samples. The
testing data were initially written on a piece of paper, transported back to the laboratory, and
transferred to the benchsheet. This original paperwork was then discarded. North Carolina
Administrative Code, 15A NCAC 2H .0805 (g) (1) states: Data pertinent to each analysis must be
maintained for five years. Notification of acceptable corrective action (i.e., a statement that a spiral
bound notebook will be used to document the pertinent information for DO and Conductivity
analyses with an implementation date of July 26, 2016) was received by email July 29, 2016. No
further response is necessary for this Finding.
Dissolved QMgen — Standard Methods, 4500 O G-2001 (Aqueous)
Comment: The Dissolved Oxygen meter was not being calibrated correctly. The meter is
calibrated by applying a correction factor based on elevation. A correction factor of 1.02 was being
used when a correction factor of 0.99 should have been applied. The NC WW/GW LC Approved
Procedure for the Analysis of Dissolved Oxygen document states: Instruments are to be
calibrated according to the manufacturer's calibration procedure prior to analysis of samples each
day compliance monitoring is performed. Notification of acceptable corrective action (i.e., a
statement that a correction factor of 0.99 was used for calibration effective July 21, 2016 and that
the benchsheets were updated to reflect this change and implemented July 28, 2016) was
received by email on July 29, 2016. No further response is necessary for this Finding.
Comment: The laboratory was not documenting the post analysis check. The NC WW/GW LC
Approved Procedure for the Analysis of Dissolved Oxygen document states: The following must
be documented in indelible ink whenever sample analysis is performed: true value and value
obtained for the post analysis calibration verification(s), where applicable. Notification of
acceptable corrective action (i.e., a statement that the benchsheets were updated to include the
true and measured values of the post analysis check with an implementation date of July 29,
2016) was received by email on July 29, 2016. No further response is necessary for this
Finding.
Conductivity —Standard Methods, 2510 B-1997 (Aqueous)
Comment: The laboratory was not documenting the true and measured values of the calibration
check standard. The NC WW/GW LC Approved Procedure for the Analysis of Conductivity
document states: The following must be documented in indelible ink whenever sample analysis is
performed: True value of the calibration verification check standard, value obtained and time
analyzed for the check standard (verification of ±10% recovery). Notification of acceptable
corrective action (i.e., a statement that the conductivity benchsheet was amended to include the
true value and measured value of the conductivity standard with an implementation date of July
29, 2016) was received by email July 29, 2016. No further response is necessary for this
Finding.
Comment: The laboratory was not documenting the true value and measured value of the post
analysis check standard and the time the analysis was done. The NC WW/GW Approved
Procedure for the Analysis of Conductivity document states: The following must be documented in
indelible ink whenever sample analysis is performed: True value and value obtained for the post
analysis calibration verification(s). Notification of acceptable corrective action (i.e., a statement
that the conductivity benchsheet was amended to include the true value and measured value of
the post analysis check standard with an implementation date of July 29, 2016) was received by
email July 29, 2016. No further response is necessary for this Finding.

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5388 Town of Littleton
Comment: The laboratory was not documenting pertinent information: units of measure.
Environmental sample measurements included units, but the calibration standard did not. 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,
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.
Notification of acceptable corrective action (i.e., a statement that the conductivity benchsheet
was updated to include the units of measure with an implementation date of July 29, 2016) was
received by email July 29, 2016. No further response is necessary for this Finding.
A. Finding: The Automatic Temperature Compensator (ATC) has not been verified.
Requirement: The ATC must be verified annually (i.e., every twelve months) and the
process documented. The ATC must be verified by analyzing a standard at 25 °C (the
temperature that conductivity values are compensated to) and a temperature(s) that brackets
the temperature ranges of the samples to be analyzed. This may require the analysis of a
third temperature reading that is > 25 *C. Ref: NC WW/GW LC Approved Procedure for the
Analysis of Specific Conductance (Conductivity). Please submit a copy of the ATC
verification documentation with the report reply.
Comment: The measured conductivity values must be within ±10% of the value of the
sample or standard at 25 °C. If not, corrective action must be taken.
Recommendation: It is recommended that a standard be used to perform the ATC
verification rather than an environmental sample so that the true value is known.
Chlorine, Total Residual — Hach 10014 (Aqueous)
pH — Standard Methods, 4500 H+ B-2000 (Aqueous)
Comment: The laboratory benchsheet was lacking pertinent data: Instrument identification. 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 pH documents state: The following must
documented in indelible ink whenever sample analysis is performed: Instrument Identification.
Notification of acceptable corrective action (i.e., a statement that the benchsheets were revised to
include the instrument ID numbers for the DR 2700 used for TRC and pH meter with an
implementation date of July 29, 2016) was received by email July 29, 2016. No further response
is necessary for this Finding.
Chlorine, Total Residual — Hach 10014 (Aqueous)
Comment: The laboratory benchsheet was lacking pertinent data: meter calibration time(s). The
NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine document
states: The following must be documented in indelible ink whenever sample analysis is performed:
Meter calibration and meter calibration time(s). Notification of acceptable corrective action (i.e., a
statement that the benchsheet was updated to include the time of the daily calibration verification
with an implementation date of July 29, 2016) was received by email on July 29, 2016. No further
response is necessary for this Finding.
Comment: The laboratory was not using the average of the stated range of the liquid chlorine
standards. The NC GW/WW LC Approved Procedure for the Analysis of Total Residual Chlorine
document states: If purchased standard solutions in sealed ampules with a stated range and
average value are used, the average value must be used for the true value of the standard.
Notification of acceptable corrective action (i.e., a statement that the average of the range is

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5388 Town of Littleton
recorded as the true value with an implementation date of July 26, 2016) was received by email
July 29, 2016. No response is necessary for this Finding.
B. Finding: The laboratory has not verified the instrument's factory -set calibration curve.
Requirement: Analyze a water blank to zero the instrument and then analyze a series of
five standards. The curve verification must check 5 concentrations (not counting the
blank) that bracket the range of the samples to be analyzed. This type of curve
verification must be performed at least every 12 months. The values obtained must not
vary by more than 10% of the known value for standard concentrations greater than or
equal to 50 µg/L and must not vary by more than 25% of the known value for standard
concentrations less than 50 µg/L. The overall correlation coefficient of the curve must be
>_0.995. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual
Chlorine. Please submit a copy of the calibration curve verification with the report
reply.
Recommendation: It is recommended that the annual calibration curve verification
standards have the following concentrations: 10 (or 15), 30, 50, 200 and 400 pg/L. This
will verify the analytical range used to measure the permitted discharge limit (i.e., 17 pg/L),
Proficiency Testing (PT) samples, standards and compliance samples.
pH — Standard Methods, 4500 H+ B-2000 (Aqueous)
Comment: Values were reported that exceed the method specified accuracy of 0.1 units.
Standard Methods, 4500 H+ B-2000, (6) states in part: 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 reported to 0.1 units with
an implementation date of July 27, 2016.) was received by e-mail on July 29, 2016. No further
response is necessary for this Finding.
Temperature — Standard Methods, 2550 B-2000 (Aqueous)
Comment: The laboratory was not analyzing temperature immediately. Samples were brought
into the laboratory and analyzed within 15 minutes of collection. The NC WW/GW LC Approved
Procedure for the Analysis of Temperature states: Immediate (i.e., in situ) analysis is required (40
CFR Part 136 Table II). Notification of acceptable corrective action (i.e., a statement that
Temperature analyses are now performed in -situ with a NIST certified thermometer for upstream,
downstream and effluent samples with an implementation date of July 26, 2016) was received by
email July 29, 2016. 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 Discharge Monitoring Reports (DMRs) submitted to the North
Carolina Division of Water Resources. Data were reviewed for the Town of Littleton (NPDES
permit # NC0025691) for January, March and May 2016. The following errors were noted:

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5388 Town of Littleton
Date
Parameter
Location
Value on Benchsheet
*Contract Lab Data
Value on
®MR
5/27/2016
Total Residual Chlorine
Effluent
No value recorded
31 pg/L
5/31/2016
Total Residual Chlorine
Effluent
31 pg/L
33 pg/L
5/10/2016
Total Suspended Solids
Influent
*77.3 mg/L
73.3 mg/L
5/17/2016
Total Nitrogen
Effluent
*26.0 mg/L
5.32 mg/L
3/22/2016
Temperature
Effluent
12.8°C
14.3°C
In order to avoid questions of legality, it is recommended that you contact the appropriate
Regional Office for guidance as to whether an amended DMR will be required. A copy of this
report will be made available to the Regional Office.
Values reported on the DMR without supporting documentation may be perceived as Falsified
Data or Information.
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 and implementation
dates for each corrective action.
Report prepared by: Anna Ostendorff
Report reviewed by: Tonja Springer
Date: August 16, 2016
Date: August 25, 2016