#5049_2020_0227_JMS_FINAL

Laboratory Cert. #:
5049
Laboratory Name:
Catawba County Schools
Inspection Type:
Field Municipal Maintenance
Inspector Name(s):
Jason Smith
Inspection Date:
February 27, 2020
Date Forwarded for Initial
March 16, 2020
Review:
Initial Review by:
Michael Cumbus
Date Initial Review
March 17, 2020
Completed:
❑ Insp. Initial
® Insp. Reg
Cover Letter to use:
❑Insp. No Finding
❑Corrected
❑Insp. CP
❑Insp. Reg. Delay
(to use: rt click, properties, chock)
Unit Supervisor/Chemist ll:
Todd Crawford
Date Received:
3/18/2020
Date Forwarded to Admin.:
3/24/2020
Date Mailed:
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Special Mailing Instructions:

CLOY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
5049
Mr. Morgan Williams
Catawba County Schools
P.O. Box 1010
Newton, NC 28658
NORTH CAROLINA
Environmental Quality
March 25, 2020
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW
LC) Maintenance Inspection
Dear Mr. Williams:
Enclosed is a report for the inspection performed on February 27, 2020 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.
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.
A copy of the laboratory's Certified Parameter List at the time of the audit is attached. This list
will reflect any changes made during the audit. 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] Ext. 259.
Sincerely,
Todd Crawford
Technical Assistance & Compliance Specialist
Division of Water Resources
Attachment
cc: Jason Smith, Dana Satterwhite
North Carolina Department of Environmental Quality I Division of Water Resources
4405 Reedy Creek Road 1 1623 Mail Service Center I Raleigh, North Carolina 27699-1623
NORTH CAROLINA
DWd M.1rW-to 919,733,3908

LABORATORY NAME:
NPDES PERMIT :
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
I. INTRODUCTION:
Catawba County Schools
N00051608, N00029297, NCO086304 and NCO074233
2500 N. College Ave
Newton, NC 28658
5049
February 27, 2020
Field Municipal Maintenance
Jason Smith
David McCorkle
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 02H .0800 for the analysis of environmental samples.
II. GENERAL COMMENTS:
The laboratory is responsible for facilities at four county schools and the inspection was
performed at Blackburn Elementary School. Staff were forthcoming and seemed eager to adopt
necessary changes.
All required Proficiency Testing (PT) Samples for the 2020 PT Calendar Year have not yet been
analyzed. The laboratory is reminded that results must be received by this office directly from the
vendor by September 30, 2020.
The laboratory is reminded that Standard Operating Procedure (SOP) documents are required to
be implemented by July 1, 2020. SOP templates may be found on the NC WW/GW LC website
here: https://deg.nc,gov/about/divisions/water-resources/water-resources-data/water-sciences-
home-page/laboratory-certification-branch/technical-assistance-policies Additionally, a
documented training program for current and future analysts must be implemented by August 1,
2020. These requirements and the SOP templates posted on the NC WW/GW LC website were
discussed during the inspection. Any time changes are made to laboratory procedures, the
laboratory must update the SOP document(s) and inform relevant staff. In some instances, the
laboratory may need to create an SOP to document how new functions or policies will be
implemented.

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#5049 Catawba County Schools
The laboratory is also reminded that SOPs are intended to describe procedures exactly as they
are to be performed. Use of the word "should" is not appropriate when describing requirements
(e.g., Quality Control (QC) frequency, acceptance criteria, etc.). Evaluate all SOPs for the proper
use of the word "should".
Contracted analyses are performed by Water Tech Labs, Inc. (Certification # 50).
A. Finding: Error corrections are not properly performed.
Requirement: All documentation errors shall 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; instead the correction shall be written
adjacent to the error. The correction shall be initialed by the responsible individual and the
date of change documented. Ref: 15A NCAC 02H .0805 (g) (1).
Comment: Overwriting and the use of correction fluid were observed.
E. Finding: The laboratory benchsheet is lacking required documentation: the method or
Standard Operating Procedure.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses and shall consist of: the method or
Standard Operating Procedure. Each item shall be recorded each time samples are
analyzed. Analyses shall conform to methodologies found in Subparagraph (a)(1) of this
Rule. Ref: 15A NCAC 02H .0805 (g) (2) (A).
C. Finding: The laboratory benchsheet is lacking required documentation: the laboratory
identification.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses and shall consist of: the laboratory
identification. Each item shall be recorded each time samples are analyzed. Ref: 15A
NCAC 02H .0805 (g) (2) (B).
Comment: Each facility has its own benchsheet which identifies the school where the
facility is located. However, this is the only identification on the benchsheet and does not
identify the lab performing the analyses as "Catawba County Schools".
D. Finding: The laboratory benchsheet is lacking required documentation: the instrument
identification.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses and shall consist of: the instrument
identification. Each item shall be recorded each time samples are analyzed. Ref: 15A
NCAC 02H .0805 (g) (2) (C).
E. Finding: The sample collector and/or analyst is not clearly identified on the benchsheet.

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#5049 Catawba County Schools
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses and shall consist of: the sample
collector; the signature or initials of the analyst. Each item shall be recorded each time
samples are analyzed. Ref: 15A NCAC 02H .0805 (g) (2) (D) and (E).
Comment: The sample collector/analyst initials the benchsheet in an unlabeled section
outside of the table. Documentation must clearly identify the person(s) responsible for both
sample collection and analysis.
F. Finding: The laboratory benchsheet is lacking required documentation: sample
identification.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses and shall consist of: sample
identification. Each item shall be recorded each time samples are analyzed. Ref: 15A
NCAC 02H .0805 (g) (2) (1).
Comment: Each facility has its own benchsheet which identifies the school where the
facility is located. However, the benchsheet does not indicate that the samples are effluent
samples.
G. Finding: The laboratory benchsheet is lacking required documentation: the proper units of
measure.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses and shall consist of: the proper units
of measure. Each item shall be recorded each time samples are analyzed. Ref: 15A
NCAC 02H .0805 (g) (2) (Q.
Comment: The units of measure are not documented on the calibration logs for Dissolved
Oxygen (DO), Total Residual Chlorine (TRC) and pH. The units of measure are
documented on the benchsheet, but TRC is incorrectly listed as "pg/10" and needs to be
corrected to "pg/L".
H. Finding: The laboratory benchsheet is lacking required documentation: NPDES permit
number.
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Facility name, sample site (ID or location), and permit number. Ref:
NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen (DO), NC
WW/GW LC Approved Procedure for the Analysis of pH, NC WW/GW LC Approved
Procedure for the Analysis of Temperature and NC WW/GW LC Approved Procedure for
the Analysis of Total Residual Chlorine (DPD Colorimetric by SM 4500 CI G-2011).
I. Finding: Documentation of the calibration variables for the DO meter does not include all
pertinent data.
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Calibration variables (temperature, elevation or barometric pressure
[in mmHg], and salinity). Ref: NC WW/GW LC Approved Procedure for the Analysis of
Dissolved Oxygen (DO).

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#5049 Catawba County Schools
J. Finding: The results of the Total Residual Chlorine (TRC) gel -type standard analyses are
not being accurately documented.
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Value obtained for the Daily Check Standard(s) and percent
recovery. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual
Chlorine (DPD Colorimetric by SM 4500 Cl G-2011).
Comment: The analyst analyzes the gel -type standard on the low level program but
documents a decimal in the result that is not displayed on the instrument. For example,
during the inspection, the analyst analyzed the gel standard and the meter read 162 pg/L
and stated that he would record the value as 1.62 pg/L. The analyst stated that this is how
he has always documented it and agreed that it is incorrect and that it would be correctly
documented without the decimal place.
K. Finding: The laboratory is not analyzing a Post -analysis Calibration Verification Standard
when performing analyses at multiple sample sites in a single day.
Requirement: When performing analyses at multiple sample sites in a single day, a Post -
analysis Calibration Verification Standard must be analyzed after the last sample. It is
recommended that a mid -day calibration verification be performed when samples are
analyzed over an extended period of time. The value obtained for the Post -analysis
Calibration Verification Standard must read within ±10% of the true value of the Post -
analysis Calibration Verification Standard for standards >_50 pg/L and within ±25% of its
true value for standards <50 pg/L. If the obtained value is outside of the acceptance limits,
corrective action must be taken. Ref: NC WW/GW LC Approved Procedure for the
Analysis of Total Residual Chlorine (DPD Colorimetric by SM 4500 Cl G-2011).
pH — Standard Methods, 4500 H+ B-2011 (Aqueous)
L. Finding: The laboratory is not analyzing a post -analysis check standard buffer when
performing analyses at multiple sample sites in a single day.
Requirement: When performing analyses at multiple sample sites, a post -analysis
calibration verification using the check standard buffer must be analyzed at the end of the
run. It is recommended that a mid -day check standard buffer be analyzed when samples
are analyzed over an extended period of time. The post -analysis check standard buffer(s)
must read within ±0.1 S.U. or corrective actions must be taken. If recalibration is
necessary, all samples analyzed since the last acceptable calibration verification must be
reanalyzed, if possible. If samples cannot be reanalyzed, the data must be qualified. Ref:
NC WW/GW LC Approved Procedure for the Analysis of pH.
Dissolved Ongen — Standard Methods, 4500 O G-2011 (Aqueous)
pH — Standard Methods, 4500 H+ B-2011 (Aqueous)
M. Finding: Samples are not being stirred during analysis for pH and DO.
Requirement: Samples shall be gently stirred during measurement. Ref: NC WW/GW LC
Approved Procedure for the Analysis of pH.

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#5049 Catawba County Schools
Requirement: Establish equilibrium between electrodes and sample by stirring sample to
insure homogeneity; stir gently to minimize carbon dioxide entrainment. Ref: Standard
Methods, 4500 H+ B-2011 (4) (b).
Requirement: Movement of water across the membrane (for membrane electrode
technologies) is important for accurate readings. Some probes come with stirrers for this
purpose. Measurements should be taken while the stirrer is in use or by swirling the DO
probe in the sample flow. Preferably, insert the probe into flowing conditions. If analyzed in
a container, stir gently with the probe or add a stir bar. Do not put the probe on the sides
or the bottom of the container. Ref: NC WW/GW LC Approved Procedure for the Analysis
of Dissolved Oxygen (DO).
Requirement: Provide sufficient sample flow across membrane surface to overcome
erratic response (see Figure 4500-0:4 for a typical example of the effect of stirring). Ref:
Standard Methods, 4500 O G-2011 (3) (b).
Proficiency Testing
N. Finding: Additional QC beyond what is routine for Compliance Samples is being analyzed
with PT Samples.
Requirement: Laboratories are required to analyze an appropriate PT Sample by each
parameter method on the laboratory's CPL. The same PT Sample may be analyzed by
one or more methods. Laboratories shall conduct the analyses in accordance with their
routine testing, calibration and reporting procedures, unless otherwise specified in the
instructions supplied by the Accredited PT Sample Provider. This means that they are to
be logged in and analyzed using the same staff, sample tracking systems, standard
operating procedures including the same equipment, reagents, calibration techniques,
analytical methods, preparatory techniques (e.g., digestions, distillations and extractions)
and the same quality control acceptance criteria. PT Samples shall not be analyzed with
additional quality control. They are not to be replicated beyond what is routine for
Compliance Sample analysis. Although, it may be routine to spike Compliance Samples, it
is neither required, nor recommended, for PT Samples. PT sample results from multiple
analyses (when this is the routine procedure) must be calculated in the same manner as
routine Compliance Samples. Ref: Proficiency Testing Requirements, February 19, 2020,
Revision 5, Section 3.6.
Comment: The laboratory analyzes a known QC sample from the PT vendor with PT
Samples.
Comment: Corrective -action standards, that are provided with the true values in a sealed
envelope, are not considered PT Samples and do not meet the PT requirements outlined
in 15A NCAC 02H .0800. In general, laboratories must not analyze standards with known
concentrations along with PT Samples with unknown concentrations, as this is not the
routine testing protocol for Compliance Samples. This is not to say that they cannot be
used for troubleshooting purposes before analyzing a remedial PT Sample. This would be
considered part of the corrective action plan.
0. Finding: The laboratory is not documenting the preparation of PT Samples.
Requirement: PT Samples received as ampules are diluted according to the Accredited
PT Sample Provider's instructions. It is important to remember to document the
preparation of PT Samples in a traceable log or other traceable format. The diluted PT

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#5049 Catawba County Schools
Sample then becomes a routine Compliance Sample and is added to a routine sample
batch for analysis. No documentation is needed for whole volume PT Samples which
require no preparation, however the instructions must be maintained. Ref: Proficiency
Testing Requirements, February 19, 2020, Revision 5, Section 3.6.
Comment: Dating and initialing the instruction sheet for each prepared PT Sample (i.e.,
TRC) would satisfy the documentation requirement.
P. Finding: Values less than the established reporting limit are being reported on the DMR.
Requirement: For all calibration options, the range of standard concentrations must
bracket the permitted discharge limit concentration, the range of sample concentrations to
be analyzed and anticipated PT Sample concentrations. One of the standards must have
a concentration less than the permitted Daily Maximum Limit. The lower reporting limit
concentration is equal to the lowest standard concentration. Sample concentrations that
are less than the lower reporting limit must be reported as a less -than value. Ref: NC
WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine (DPD
Colorimetric by SM 4500 Cl G-2011).
Comment: The laboratory has established a lower reporting limit of 25 pg/L. Samples with
concentrations less than that must be reported as < 25 pg/L on the DMR.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) and contract laboratory reports to Discharge Monitoring Reports (DMRs) submitted to the
North Carolina Division of Water Resources. Data were reviewed for Bandys High School
(NPDES permit # NC0051608), Fred T. Foard High School (NPDES permit # NC0029297), Mill
Creek Middle School (NPDES permit # NC0086304) and Blackburn Elementary School
(NPDES permit # NC0074233) for August, September and October 2019. The following errors
were noted:
Date
Parameter
Location
Value on
Benchsheet
Value on DMR
9/5/19
Temperature
Fred T. h Foard High
21.8 °C
21.3 °C
School Effluent
9/27/19
Temperature
Bandys High School
21.3 °C
No Value
Effluent
Reported
To avoid questions of legality, it is recommended that you contact the appropriate Regional
Office for guidance as to whether an amended DMR(s) will be required. A copy of this report
will be made available to the Regional Office.
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

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#5049 Catawba County Schools
includerespond to all Findings and supporting documentation, implementation
?nd steps taken . prevent - for each corrective action.
Report prepared by: Jason Smith Date: March 16, 2020
Report reviewed by: Michael Cumbus Date: March 17, 2020

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