#153 - 10 - 2011 - FINAL

Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
December 12, 2011
153
Ms. Debra Tunstell
City of Lincolnton WWTP Lab
P.O. Box 617
Lincolnton, NC 28092
SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Ms. Tunstell:
Enclosed is a report for the inspection performed on October 26, 2011 by Chet Whiting. I apologize for the
delay in getting this report to you. Where finding(s) are cited in this report, a response is required. Within 30
days of receipt, please supply this office with a written item for item description of how these finding(s) were
corrected. 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 828-296-4677.
Sincerely,
COY'
Gary Francies
Unit Supervisor
Laboratory Section
CC: Chet Whiting
Master files
DENR DWQ Laboratory Section NC Wastewater/Groundwater Laboratory Certification Branch
1623 Mail Service Center, Raleigh, North Carolina 27699-1623
Location: 4405 Reedy Creek Road. Raleigh, North Carolina 27607-6445
Phone: [phone] \ FAX: [phone]
Internet: www.dwglab.org
i
An Equal Opportunity \ Affirmative Action Employer Customer Service:1-877-623-6748 www.ncwaterquality.org

. INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
153
Laboratory Name:
City of Lincolnton WWTP Lab
Inspection Type:
Municipal Maintenance
Inspector Name(s):
Chet Whiting
Inspection Date:
October 26, 2011
Date Report Completed:
November 28, 2011
Date Forwarded to Reviewer: November 29, 2011
RCyieyyed by:
Jason Smith
Date Review Completed:
December 2, 2011
Cover Letter to use: _
Insp. Initial X Insp. Reg. _ Insp. No Finding _ Insp. CP _Corrected
Unit Supervisor:
Gary Francies
Date Received:
12/6/2011
Date Forwarded for mailing:
12/9/2011
Date Mailed:,
L

On -Site Inspection Report
LABORATORY NAME:
NPDES PERMIT #:
CERTIFICATE #:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
City of Lincolnton WWTP Lab
NCO025496
P.O. Box 617
Lincolnton, NC 28092
153
October 26, 2011
Municipal Maintenance
Chet Whiting
Debra Tunstell
This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for
the analysis of environmental samples.
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The laboratory was clean and well organized. The facility has all the equipment necessary to perform the
analyses.
The requirements associated with Findings A and B are new policies that have been implemented by our
program since the last inspection.
Comment: The Conductivity and Dissolved Oxygen temperature sensors had not been checked within
12 months and the corrections were not posted. The pH meter temperature sensor, thermometers for
the TSS oven, refrigerator, water bath and measurement of temperature had been checked but the
corrections were not posted. North Carolina Wastewater/Groundwater Laboratory Certification Policy
states: All thermometers and temperature measuring devices must be checked every 12 months
against a NIST certified or NISI traceable thermometer and the process documented. To check a
thermometer or the temperature sensor of a meter, read the temperature of the thermometer/meter
against a NIST certified or NIST traceable thermometer and record the two temperatures. The
calibration must be performed at a temperature that corresponds to the temperature used by the
incubator, refrigerator, freezer, etc. In the case of temperature measuring devices used to perform
variable temperature readings the calibration must be performed at a temperature range that
approximates the range of the samples. The thermometer/meter readings must be less than or equal
to 10C from the NIST certified or NIST traceable thermometer reading. The documentation must
include the .serial number of the NIST certified thermometer or NIST traceable thermometer that was
used in the comparison. Also make any corrections to the data and document any correction that
applies (even if zero) on both the thermometer/meter and on a separate sheet to be filed. (NOTE:
Other certified laboratories may provide assistance in meeting this requirement.) Acceptable corrective

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#153 City of Lincolnton WWTP Lab
action was performed on -site (i.e., the Conductivity and Dissolved Oxygen meter temperature sensors
were checked as required and all corrections were posted). No further response is necessary for this
finding.
Suspended Solids — Standard Methods, 18th Edition, 2540 D
Comment: On 5/2/11, the time that Total Suspended Solids (TSS) samples were removed from the
drying oven was not documented. This was the only instance observed in the data reviewed.
A. Finding: The laboratory is not basing the reporting limit on the minimum weight gain required by
the method.
Requirement: Choose sample volume to yield between 2.5 and 200 mg dried residue. To
obtain the required residue yield, successive aliquots of samples may be added to the same
dish after evaporation or adjust reporting level based upon the weight gain and sample volume
used. The minimum reporting value is established at 2.5 mg/L based upon a sample volume
used of 1000 mL. Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy
based upon Standard Methods, 20th and 21 st Editions, 2540 C. (3) (d) and 2540 B. (3) (b).
Comment: For the instances observed, 500 mL sample was analyzed, and less than 2.5 mg of
dried residue was reported. Based on that volume the value reported would be <5 mg/L.
Suspended Solids — Standard Methods, 181h Edition, 2540 D
Fecal Coliform — Standard Methods, 18th Edition, 9222 D
Recommeindation: The TSS and Fecal Coliform duplicate Relative Percent Differences (RPD)
acceptance criteria were as large as to 65% due to low sample concentrations. It is recommend that the
laboratory consider an alternate method for evaluating low level TSS and Fecal Coliform duplicates that
reflects a more realistic assessment. Standard Methods, 21st Edition, 1020 B. (12) (b) and 9020 B. (8) (b)
(1 — 5) use a statistical approach to evaluate duplicates. Another option could be a two tiered system,
with different acceptance criteria based upon the concentration or value of the result. For example, the
acceptance criterion of TSS results below 10 mg/L could be ± 2 mg/L while retaining the current
acceptance criterion for results above 10 mg/L. Similarly, the Fecal Coliform acceptance criterion for
samples with fewer than 20 colonies could be ± 5 colonies (using actual colonies, rather than the
calculated result per 100 mL) while retaining the current acceptance criterion for 20-60 colonies.
Comment: While no instances were observed in the data that was reviewed please be aware of our
policy when laboratory established or method Quality Control (QC) limits are exceeded:
When quality control (QC) failures occur, the laboratory must attempt to determine the source of the
problem and must apply corrective action. Part of the corrective action is notification to the end user. If
data qualifiers are used to qualify samples not meeting QC requirements, the data may not be useable
for the intended purposes. It is the responsibility of the laboratory to provide the client or end -user of
the data with sufficient information to determine the usability of the qualified data.
Where applicable, a notation must be made on the Discharge Monitoring Report (DMR) form, in the
comment section, when any required sample quality control does not meet specified criteria and another
sample cannot be obtained. Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy
based upon Standard Methods, 20th Edition, 1020 B. (14).
Although this is a recommendation please include a written response stating which duplicate
QC evaluation option is going to be used for the above cited methods.

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#153 City of Lincolnton WWTP Lab
Ammonia Nitrogen — Standard Methods, 18th Edition, 4500 NH3 F
B. Finding: The volume of Ionic Strength Buffer added to samples, blanks and standards is not
documented.
Requirement: Record volume of 10N NaOH added in excess of 1 mL. Ref: Standard Methods,
18th Edition, 4500 NH3-N F. (4) (e) and (5).
Comment: The volume of 10N NaOH used is a part of the calculation to determine the
concentration of NH3-N.
C. Finding: Units of measure are not documented on the pH calibration log.
Requirement: All laboratories must use printed laboratory bench worksheets that include a
space to enter the signature or initials of the analyst, date of analyses, sample identification,
volume of sample analyzed, VQIIle f1olll the IIIGGIslllelllellt system, lalaor cllld final VcIUFZl to be
reported and each item must be recorded each time samples are analyzed. The date and time
BOD and coliform samples are removed from the incubator must be included on the laboratory
worksheet. Ref: 15A NCAC 2H .0805 (a) (7) (H).
Total Residual Chlorine — Standard Methods, 18th Edition, 4500 Cl G
Recommendation: The current Total Residual Chlorine (TRC) curve verification was performed using
the following concentrations: 20, 50, 75, 150 and 200,ug/L. In order to increase confidence the area of
likely sample concentrations, it is recommended that the laboratory verify the internal calibration using
the concentrations: 20, 30, 50, 200 and 400 ,ug/L the next time the instruments internal curve is
verified. This will also verify the analytical range used to measure Proficiency Testing (PT) samples .
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 NPDES permit # NC0025496 for May and June 2011. No transcription errors were
detected. The facility appears to be doing a good job of accurately transcribing data.
ONOOIM�„•�
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: Chet Whiting Date: November 28, 2011
Report reviewed by: Jason Smith Date: December 2, 2011