#71 - 02 - 2010 - FINAL

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North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
April 29, 2010
71
Ms. Elisa Triplett
Lower Creek WWTP Laboratory.
P.O. Box 958
Lenoir, NC 28645
SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Ms. Tripfettt:
Dee Freeman
Secretary
Cnciosea is a report Tor the inspection pertormed on February 4, 2010 by Mr. 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 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 coloy of this report by email or if you have
questions or need additional information please contact me at 828-296-4677.
Sincerely,
Gary Francies
Unit Supervisor
Laboratory Section
CC: Jason Smith
Asheville Regional Office
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] t FAX: [phone]
Internet: www,dwglab.org
One
NofthCarolina
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An Equal opportunity t Ailinnative faction Employer Customer Service: 1-877-623-6748 www.ncwaterquality.org

LABORATORY NAME:
NPDES PERMIT M
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
Lower Creek WWTP Laboratory
NC0023981, NC0023736, and NCO044164
P.O. Box 958
Lenoir, NC 28645
71
February 4, 2010
Municipal Maintenance
Jason Smith and Chet Whiting
Elisa Triplett, Kevin Matheson, and Lowell Graves
This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for
the analysis of environmental samples.
The laboratory was clean and well organized. The facility has all the equipment necessary to perform the
analyses. The laboratory analyzes samples for both of Lenoir's Wastewater Treatment Plants (WWTP)
as well as the Water Treatment Plant (WTP). The laboratory does a good job of coordinating the
sampling of all three facilities.
Findings B, C, D, E, F, G, and H are new policies that have been implemented by our program since the
last inspection.
Ill. FINDINGS, REQUIREMENTS, COMMENTSRECOMMENDATIONJ
Documentation
A. Finding: The laboratory needs to increase the documentation of materials and reagents used or
made 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 (where specified). 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 primary standards, chemicals, reagents, and materials used for a period
of five years. Consumable materials such as pH buffers, lots of pre -made standards and/or
media, solids and bacteria filters, etc. are included in this requirement. Ref: North Carolina
Wastewater/Groundwater Laboratory Certification Policy.

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#71 Lower Creek WWTP Laboratory
Comment: The laboratory has a good system of traceability in place for its own materials and
reagents. However, this system also needs to be applied to reagents and materials used by the
other facilities which analyze samples in the field.
B. Finding: Numerous instances of improper error corrections 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: North Carolina
Wastewater/Groundwater Laboratory Certification Policy.
Total Residual Chlorine — Standard Methods, 20#h Edition, 4500 Cl G
Comment: The standard curve verification meets the requirements for linearity; however it appears that
the accuracy near the reporting limit (20 lag/L) is questionable for the meter used at the Lower Creek
tWWTP. A result of 36 lag/L was obtained on a standard with a true value of 20 lag/L. The y intercept for
the curve is calculated to be 11.8 pag/L, which is over half of the value of the lowest standard. Additionally,
based upon the requirements in the Technical Assistance for Field Analysis of Total Residual Chlorine
(TRC), which applies to Field Laboratories and analyses performed in a field setting, standards below 50
lag/L must be ± 25% of the true value. The laboratory performed the annual curve verification on February
8, 2010 and obtained acceptable results.
Recommendation: The standard curve verification for the WTP was performed by reading the
absorbance of each standard. It is recommended that the value obtained for each standard be recorded.
This would allow a better evaluation of the curve based upon the acceptance criteria of ± 10% for values
>_ 50 lag/L and ± 25% for values < 50 pag/L.
C. Finding: The time of analysis of the gel standard is not documented.
Requirement: The time the calibration check was performed must be documented whenever
sample analysis is performed. Ref: Technical Assistance for Field Analysis of Total Residual
Chlorine.
D. Finding: Data values are reported to two decimal places.
Requirement: A variance of ± 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. Ref: Standard Methods, 20th Edition, 4500 H+ B. (6).
Conductivity — Standard Methods, 20th Edition, 2510 B
Recommendation: An acceptable recovery range of ± 25% is recommended for low range standards.
Settleable Solids — Standard Methods, 20th Edition, 2540 F
E. Finding: The stirring or spinning of the cone after 45 minutes is not documented. This is
considered pertinent information.

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#71 Lower Creek WWTP Laboratory
Requirement: Settle for 45 minutes, gently agitate sample near the sides of the cone with a
rod or by spinning, settle 15 minutes longer, and record volume of settleable solids in the cone
as milliliters per liter. Ref: Standard Methods, 20t" Edition, 2540 F. (3) (a).
Requirement: All analytical data pertinent to each certified analysis must be filed in an orderly
manner so as to be readily available for inspection upon request. Ref: 15A NCAC 2H .0805 (a)
(7) (A):
Total Suspended Solids — Standard Methods, 20" Edition, 2540 D
Recommendation: The laboratory currently dries the filters for sixteen hours (overnight). It is
recommended that the filters be dried for one hour during the next annual drying study, rather than for
sixteen hours as in the current drying study. The laboratory could still maintain their current daily drying
time, but proving that one hour is sufficient would give some flexibility in case a sample result is needed
more quickly.
Total Phosphorus — Standard Methods, 201" Edition, 4500 P E
NO + NO- Nitrogen —Standard Methods, 201" Edition, 4500 NO3 E
Ammonia Nitrogen — Standard Methods, 20t" Edition, 4500 NH3 D
Total neldahl Nitrogen — Standard Methods, 20t" Edition, 4500 NoRc B and 4500 NH3 D
Recommendation: It is recommended that after instrument calibration the reporting limit standard be
analyzed. Suggested acceptance criterion is ± 25%. This will further document the accuracy of data at
low concentrations.
F. Finding: A blank is not analyzed at the end of the sample 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.). kef: North Carolina Wastewater/Groundwater laboratory Certification Policy based upon
Standard Methods, 201" Edition, 1020 B. (10) (c), 3020 B. (2) (b), and 4020 B. (2).
zrrinlin
G. Finding: The volume of 1 ON NaOH added to samples and standard is not documented.
Requirement: Record volume of 10N NaOH added. Ref: Standard Methods, 20t" Edition, 4500
NH3 D. {4) (e).
H. Finding: After the addition of the 10 N NaOH, the pH is not verified and documented to be
greater than 11.
Requirement: Add a sufficient volume of 10N NaOH solution to raise pH above 11. Ref:
Standard Methods, 20t" Edition, 4500 NH3 D. (4) (b).
Requirement: Supporting records shall be maintained as evidence that these practices are being
effectively carried out. Ref: 15A NCAC 2H .0805 (a) (7).

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#71 Lower Creek WWTP Laboratory
Comment: When the volume of 1ON NaOH used for the samples is different than that used for
the calibration standards, this must be compensated for in the following calculation:
mgNH3—NIL=AXBX 100+D
(100 + C)
A= Dilution Factor
B= Concentration of NH3-NIL, mg/L, from calibration curve
C= Volume of 1ON NaOH added to the calibration standards, mL
D= Volume of ION NaOH added to sample, mL
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing laboratory bench sheets and contract lab reports to Discharge
Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data were
reviewed for Lower Creek WWTP (NPDES permit # NCO023981) and Gunpowder Creek (NPDES
permit # NCO023736) for July, 2009. The following error was noted:
Date
Parameter
Location
Value on
Benchsheet
Value on DMR
7-24-09
Dissolved Oxygen
Gunpowder Creek Effluent
7,49
6.7
In order to avoid questions of legality, it is recommended that you contact the appropriate Regional
Office for guidance as to whether an amended Discharge Monitoring Report will be required. A copy of
this report will be forwarded to the Regional Office,
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: Jason Smith Date: March 17, 2010
Report reviewed by: Chet Whiting Date: April 13, 2010