#5060_12_2014_FINAL

VA I
A*41
N,orth Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
January 13, 2015
5060
Mr. Robert Pearson
City of Lincolnton WTP
P.O. Box 617
Lincolnton, NC 28093
Donald R. van der Vaart
Secretary
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Pearson:
Enclosed is a report for the inspection performed on December 10, 2014 by Jason Smith. 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. 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 us at (828)
296-4677.
Attachment
cc: Master file
Jason Smith
Sincerely,
Gary Francies, Technical Assistance/Compliance Specialist
Division of Water Resources
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: www,dMiab.org
An Equal Opportunity r, Affirmative Action Employer

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #: 5060
Laboratory Name: City of Lincolnton WTP
Inspection Type: Field Maintenance
Inspector Name(s): Jason Smith
Inspection Date: December 10, 20
Date Report Completed: January 7, 2015
Date Forwarded to Reviewer: January 7, 2015
Reviewed by: Todd Crawford
Date Review Completed: January 7, 2015
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: 1/8/2015
Date Forwarded to Linda: 1/12/2014
Date Mailed: 1/13/2015 LC
please send to Wes Bell in MRO wes.bell(a.ncdenr.gov

On -Site Inspection Report
LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
I. INTRODUCTION:
City of Lincolnton WTP
NCO085588
P.O. Box 617
Lincolnton, NC 28093
5060
December 10, 2014
Field Maintenance
Jason Smith
Robert Pearson and Todd Cochrane
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 facility has all the equipment necessary to perform the analyses. Proficiency Testing (PT) samples
have been analyzed for all certified parameters for the 2014 proficiency testing calendar year and the
graded results were 100% acceptable.
Contracted analyses are performed by Prism Laboratories, Inc. (Certification #402).
Current quality assurance policies for Field Laboratories and approved procedures for the analysis of
the facility's currently certified parameters were provided at the time of the inspection.
The requirements associated with Findings B, D, E, G, H, and I have been implemented by our program
since the last inspection.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
A. Finding: Some instances of overwriting as a means of error correction were observed.
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 Policies for
Field Laboratories.

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#5060 City of Lincolnton WTP
B. Finding: The laboratory needs to increase the documentation of purchased materials and
reagents, as well as documentation of standards and reagents prepared in the laboratory.
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.
Comment: The underlined portion of the above requirement refers to the laboratory prepared
Potassium Permanganate for Total Residual Chlorine (TRC) curve verification.
Comment: The laboratory has an acceptable traceability log for drinking water analysis reagents
which may also be used for wastewater analysis reagents.
C. Finding: All original records were not on file.
Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A NCAC
2H .0805 (g) (1).
Comment: The testing data is initially written on a piece of paper and then transferred to the
benchsheet. This original paperwork is then discarded.
D. Finding: Instrument identification is not documented on the benchsheets for TRC.
Requirement: The following must be documented in indelible ink whenever sample analysis is
performed: Instrument identification. Ref: NC WW/GW LC Approved Procedure for the Analysis of
Total Residual Chlorine.
E. Finding: The true value of the TRC gel standard is not documented on the benchsheet.
Requirement: The following must be documented in indelible ink whenever sample analysis is
performed: True value of the check standard. Ref: NC WW/GW LC Approved Procedure for the
Analysis of Total Residual Chlorine.
F. Finding: Units of measure for pH (Standard Units or S.U.) are not documented on the
benchsheet and calibration log.
Requirement: The field benchsheets must provide a space for the signature or initials of the
analyst, and proper units of measure for all analyses. Ref: 15A NCAC 2H .0805 (g) (1).
Proficiency Testing
G. Finding: The laboratory is not analyzing PT samples in the same manner as environmental
samples.

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#5060 City of Lincolnton VVTP
Requirement: 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. Ref: Proficiency
Testing Requirements, February 20, 2012, Revision 1.2.
Comment: The laboratory's common practice was to analyze a known standard along with the
PT sample as additional quality control. Since this is not performed with all environmental
samples, it is considered additional quality control. However, known samples are recommended
when analyzing remedial PT samples as part of the troubleshooting and corrective action
process.
H. Finding: The laboratory is not documenting Proficiency Testing (PT) sample analyses in the
same manner as environmental samples.
Requirement: All PT sample analyses must be recorded in the daily analysis records as for any
environmental sample. This serves as the permanent laboratory record. Ref: Proficiency
Testing Requirements, February 20, 2012, Revision 1.2.
Comment: This means that the PT analyses must be documented on a benchsheet in the
same manner as daily samples.
I. Finding: The preparation of PT samples is not documented.
Requirement: 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. Ref: Proficiency Testing Requirements, February 20,
2012, Revision 1.2.
Comment: Dating and initialing the instruction sheet for the preparation of the TRC PT would
satisfy the documentation requirement.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing field testing records and contract lab reports to Discharge
Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Resources. Data were
reviewed for the City of Lincolnton WTP (NPDES permit #NC0085588) for July, August, September,
and October, 2014. 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 will help this la
requirements. The inspector would like to thank the
data review process. Please respond to all findings.
Report prepared by: Jason Smith
Report reviewed by: Todd Crawford
b
to produce quality data and meet certification
staff for its assistance during the inspection and
Date: January 7, 2015
Date: January 7, 2015