#86 12-Final

INSPECTION REPORT ROUTING SHEET

To be attached to all inspection reports in-house only.

Laboratory Cert. #: #86

Laboratory Name: City of Asheboro WWTP

Inspection Type: Municipal Maintenance

Inspector Name(s): Jeffrey R. Adams

Inspection Date: November 27, 2012

Date Report Completed: November 29, 2012

Date Forwarded to Reviewer: November 29, 2012

Reviewed by: Jason Smith

Date Review Completed: December 6, 2012

Cover Letter to use: Insp. Initial Insp. Reg.
Insp. No Finding Insp. CP
Corrected

Unit Supervisor: Dana Satterwhite

Date Received: December 7, 2012

Date Forwarded to Linda: December 14, 2012

Date Mailed: December 14, 2012

_____________________________________________________________________

On-Site Inspection Report

LABORATORY NAME: City of Asheboro WWTP

NPDES PERMIT # NC0026123

ADDRESS: P.O. Box 1106
Asheboro, NC 27293

CERTIFICATE #: 86

DATE OF INSPECTION: November 27, 2012

TYPE OF INSPECTION: Municipal Maintenance

AUDITOR(S): Jeffrey R. Adams

LOCAL PERSON(S) CONTACTED: Bernadine Wardlaw, Judy Smith and Dina Tutterow

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 environmental samples.

II. GENERAL COMMENTS:

The laboratory was clean and well organized. The facility has all the equipment necessary to perform the
analyses. The data was filed in an orderly manner and readily available for review. The laboratory is to be
commended for implementing the new traceability and the new Total Suspended Residue reporting limit
requirements prior to the inspection. Some quality control procedures need to be implemented.

The laboratory is reminded that any time changes are made to laboratory operations; the laboratory must
update the Quality Assurance (QA)/Standard Operating Procedures (SOP) document(s). Any changes
made in response to the Findings, Recommendations or Comments listed in this report must be
incorporated to insure the method is being performed as stated, references to methods are accurate, and
the QA and/or SOP document(s) is in agreement with approved practice and regulatory requirements. In
some instances, the laboratory may need to create a SOP to document how new functions or policy will be
implemented.

On May 18, 2012, EPA promulgated changes to the list of Clean Water Act (CWA) methods at 40 CFR Part
136.3. This action, referred to as the Methods Update Rule (MUR) approves new methods, or changes to
existing methods, that affects over 100 EPA methods, Standard Methods, ASTM methods, and other test
procedures in Part 136 of Title 40 of the Code of Federal Regulations (CFR). The rule also contains a
number of clarifications relating to approved methods, sample preservation and holding times, and method
modifications. The final rule may be found at: http://water.epa.gov/scitech/methods/cwa/updateindex.cfm.
The North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) program will be
asking certified laboratories to move toward implementation of the new rule with changes fully implemented
by the end of 2012. Each laboratory will need to review the MUR and evaluate its effect on cu rrent
laboratory practices. These changes must be made in the laboratory’s Standard Operating Procedures and
in Quality Manuals, as well as any other place where the method is cited, e.g., reports, benchsheets, logs,
etc. During this transition period, inspection reports will refer to the methods employed at the laboratory at
the time of the inspection, but will reference the requirements in the most recently approved version of the
method. Any difficulties encountered with meeting the requirements of these references by the date due
may be addressed in the written corrective action response.
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#86 City of Asheboro WWTP

Contracted analyses are performed by Environment 1, Inc. (Certification #10) and Pace Analytical Services,
Inc. (Certification #40).

The laboratory was given a packet containing North Carolina Laboratory Certification quality control
requirements and policies during the inspection.

The requirements associated with Findings A and C are new policies that have been implemented by our
program since the last inspection.

III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:

BOD – Standard Methods, 5210 B - 2001

A. Finding: Extra nutrient, mineral, and buffer solutions are not added to the Biochemical Oxygen
Demand (BOD) bottles containing more than 67% (i.e., > 201 mL) sample.

Requirement: When a bottle contains more than 67% of the sample after dilution, nutrients
may be limited in the diluted sample and, subsequently, reduce biological activity. In such
samples, add the nutrient, mineral, and buffer solutions (3a through e) directly to individual
BOD bottles at a rate of 1 mL/L (0.33 mL/300-mL bottle) or use commercially-prepared
solutions designed to dose the appropriate bottle size. Ref: Standard Methods, 5210 B-2001,
(5) (c) (2).

Comment: Dilution water prepared as normal with nutrient, mineral, and buffer solutions would
still be used in the BOD bottles. For the bottles containing more than 67% sample, extra
nutrient, mineral, and buffer solutions would be added in addition to the dilution water.

Recommendation: Rather than pipetting 0.33 mL of each reagent into the BOD bottle, it is
recommended that commercially prepared nutrient buffer pillows for 300 mL bottles be used.

COD – Standard Methods, 5220 D - 1997
Cyanide – Standard Methods, 4500 CN E - 1999 (Total)
Total Kjeldahl Nitrogen – Standard Methods, 4500 Norg C - 1997
Total Kjeldahl Nitrogen – Standard Methods, 4500 NH3 E - 1997
Nitrate – Nitrite – Standard Methods, 4500 NO3 E - 2000
Nitrite Nitrogen – Standard Methods, 4500 NO2 B - 2000
Total Phosphorous – Standard Methods, 4500 P E - 1999

B. Finding: The laboratory is not analyzing a calibration blank and a calibration verification standard
after calibration, every 10 samples and at the end of the run.

Requirement: The calibration blank and calibration verification standard (mid-range) must be
analyzed initially (i.e., prior to sample analysis), after every tenth sample and at the end of each
sample group to check for carry over and calibration drift. If either fall outside established quality
control acceptance criteria, corrective action must be taken (e.g., repeating sample determinations
since the last acceptable calibration verification, repeating the initial calibration, etc.). Ref: North
Carolina Wastewater/Groundwater Laboratory Certification Policy based upon Standard
Methods, 20th Edition, 1020 B. (10) (c), 3020 B. (2) (b), and 4020 B. (2).

Ammonia – Standard Methods, 4500 NH3 D - 1997

C. Finding: The laboratory is not analyzing matrix spikes.

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#86 City of Asheboro WWTP

Requirement: Unless the referenced method states a greater frequency, spike 5% of samples on a
monthly basis. Laboratories analyzing less than 20 samples per month must analyze at least one
matrix spike each month samples are analyzed. Prepare the matrix spike from a reference source
different from that used for calibration unless otherwise stated in the method. If matrix spike results
are out of control, the results must be qualified or the laboratory must take corrective action to rectify
the effect, use another method, or employ the method of standard additions. When the method of
choice specifies matrix spike performance acceptance criteria for accuracy, and the laboratory
chooses to develop statistically valid, laboratory-specific limits, the laboratory-generated limits
cannot be less stringent than the criteria stated in the approved method.

The volume of spike solution used in matrix spike preparation must in all cases be ≤ 10% of the total
matrix spike volume. It is preferable that the spike solution constitutes ≤ 1% of the total matrix spike
volume so that the matrix spike can be considered a whole volume sample with no adjustment by
calculation necessary. If the spike solution volume constitutes >1% of the total sample volume, the
sample concentration or spike concentration must be adjusted by calculation. Ref: North Carolina
Wastewater/Groundwater Laboratory Certification Policy.

Comment: The laboratory had implemented matrix spiking for all parameters except Ammonia.

Total Residual Chlorine – Standard Methods, 4500 Cl G – 2000

Recommendation: The laboratory’s National Pollutant Discharge Elimination System (NPDES) Permit limit
is 17 µg/L for Total Residual Chlorine. It is recommended that the laboratory verify the internal calibration
using the concentrations: 15, 30, 50, 200 and 400 µg/L. This will verify the analytical range used to measure
Proficiency Testing (PT) samples as well as environmental samples.

Recommendation: It is recommended that the values obtained not vary by more than 10% of the known
value for standard concentrations greater than or equal to 50 g/L and not vary by more than 25% of the
known value for standard concentrations less than 50 g/L. The overall correlation coefficient of the curve
must be ≥0.995.

Comment: The laboratory is currently verifying the stored curve using 10, 20, 50, 100 and 200 µg/L
standards but has been diluting the Proficiency Testing (PT) samples when the concentrations exceed the
highest standard of 200 µg/L. Expanding the verification curve to 400 µg/L will eliminate the need for
sample dilution and lessen the chance of a dilution error.

IV. PAPER TRAIL INVESTIGATION:

The paper trail consisted of comparing laboratory benchsheets and contract lab reports to Discharge
Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data were reviewed
for the City of Asheboro WWTP Laboratory (NPDES permit #NC0026123 ) for August, September and
October, 2012. No transcription errors were detected. 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 lab to produce
quality data and meet certification requirements. The inspector would like to thank the staff for its assistance
during the inspection and data review process. Please respond to all findings.

Report prepared by: Jeffrey R. Adams Date: November 29, 2012
Report reviewed by: Jason Smith Date: December 6, 2012