#5406_2016_0726_BS_FINAL

W a ter Resour-c es
ENVIRONMENTAL QUALITY
August 17, 2016
5406
Mr. Bergie Speaks
Wilkes County Board of Education
613 Cherry Street
N. Wilkesboro, NC 28659-
PAT MCCRORY
DONALD R. VAN DER VAART
S. JAY ZIMMERMAN
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Speaks:
Enclosed is a report for the inspection performed on July 26, 2016 by Beth Swanson and Gary Francies.
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.
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].
Sincerely,
Gary Francies, Technical Assistance/Compliance Specialist
Division of Water Resources
Attachment
cc: Beth Swanson
master file

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
Laboratory Name:
Inspection Type:
Inspector Name(s):
Inspection Date:
Date Report Completed:
Date Forwarded to Reviewer:
Reviewed by:
Date Review Completed:
Cover Letter to use:
Unit Supervisor/Chemist III:
Date Received:
Date Forwarded to Admin:
Date Mailed:
Special Mailing Instructions:
5406
Wilkes County Board of Education
Field Maintenance
Beth Swanson, Gary Francies
Julv 26.2016
August 4, 2016
Auaust 4. 2016
Tonga Springer
Auaust 12. 2016
❑ Insp. Initial ® Insp.• Reg.
❑ Insp. No Finding ❑ Insp. CP
❑ Corrected ❑ Insp. Reg. Delay
Gary Francies
August 15, 2016
August 16, 2016
August 17, 2016

On -Site Inspection Report
LABORATORY NAME: Wilkes County Board of Education
NPDES PERMIT #: NC0046426, NC0038709, NC0075515, NCO046418 and
NCO076066
ADDRESS: 211 School Bus Drive
North Wilkesboro, NC 28656
CERTIFICATE #: 5406
DATE OF INSPECTION: July 26, 2016
TYPE OF INSPECTION: Field Maintenance
AUDITOR(S): Beth Swanson and Gary Francies
LOCAL PERSON(S) CONTACTED: Thomas Spicer
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.
IL GENERAL COMMENTS:
The laboratory analyst was forthcoming and eager to address any issues that will help the
facility meet Certification requirements. Records are well organized and easy to retrieve.
All required Proficiency Testing (PT) samples have been analyzed for the 2016 PT calendar year
and the graded results were 100% acceptable.
Requirements that reference 15A NCAC 2H .0805 (g) (1), stating "Data pertinent to each analysis,
must be maintained for five years. Certified Data must consist of date collected, time collected,
sample site, sample collector, and sample analysis time. The field benchsheets must provide a
space for the signature or initials of the analyst and proper units of measure for all analyses", are
intended to be a requirement to document meter calibration. Although the requirement list is not
all inclusive, it is intended to address the need to document all pertinent information for historical
reconstruction of data. It is not intended to imply that existing records are not adequately
maintained unless the Finding speaks directly to that.
Contracted analyses are performed by Water Tech Labs, Inc. (Certification # 50).
Current Quality Assurance Policies for Field Laboratories and Approved Procedure documents
for the analysis of the facility's currently certified methods were provided at the time of the
inspection.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:

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#5406 Wilkes County Board of Education
Documentation
A. Finding: The laboratory needs to increase the documentation of purchased materials.
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. 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: Utilization of the laboratory supply receipt log supplied by the auditor on July
28, 2016 via email would fulfill this documentation requirement.
D. Finding: The laboratory benchsheet was lacking pertinent data: analyst's initials.
Requirement: Data pertinent to each analysis must be maintained for five years.
Certified Data must consist of date collected, time collected, sample site, sample
collector, and sample analysis time. The field bench sheets must provide a space for the
signature or initials of the analyst, and proper units of measure for all analyses. Ref: 15A
NCAC 02H .0805 (g) (1).
Comment: Utilization of the benchsheets supplied by the auditor on July 28, 2016 via
email would fulfill this documentation requirement.
C. Finding: Error corrections are not performed properly.
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-OutO, 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.
Comment: Wite-Out@ was occasionally used and corrections were not initialed and
dated by the person performing the correction.
Proficiency Testing
D. Finding: The preparation of Proficiency Testing (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 Total
Residual Chlorine PT would satisfy the documentation requirement.

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#5406 Wilkes County Board of Education
E. 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: The analysis of PT samples is designed to evaluate the entire process used to
routinely report environmental analytical results; therefore, PT samples must be analyzed
and the process documented in the same manner as environmental samples. Utilization of
the notes column to record analysis time, sample identification and result, on the
calibration logs supplied by the auditor on July 28, 2016 via email would fulfill these
documentation requirements.
pH — Standard Methods, 4500 H+B-2000 (Aqueous)
F. Finding: The pH meter is not consistently calibrated each day before use.
Requirement: Instruments are to be calibrated according to the manufacturer's calibration
procedure prior to analysis of samples each day compliance monitoring is performed. Ref:
NC WW/GW LC Approved Procedure for the Analysis of pH.
Comment: The analyst self -reported that the pH meter is not always calibrated before
use. Due to staffing issues and inclement weather, the analyst will sometimes analyze
samples without first going to the laboratory where the pH buffers and calibration log are
kept, to calibrate the instrument.
Recommended: It is recommended that extra buffers and a calibration log be kept in all
work vehicles so that a trip to the laboratory is not necessary to complete calibration.
Please note that aliquots of pH buffer must be properly labeled to provide traceability.
G. Finding: The pH meter is not recalibrated if the check standard does not read.within ±0.1
S.U.
Requirement: The check standard buffer must read within ±0.1 S.U. to be acceptable. If
the meter verification does not read within ±0.1 S.U., the meter must be recalibrated
before any samples are analyzed. Ref: NC WW/GW LC Approved Procedure for the
Analysis of pH.
Comment: The analyst would monitor the check standard value but stated that when it
was about 7.15 S.U., he would discard the buffer portion that was being reused and pour a
fresh aliquot for the next day. The meter was not recalibrated or a fresh aliquot of buffer
checked when the reading was more than ±0.1 S.U. from the known value.
Recommendation: It is recommended that portions of the buffer solutions not be used for
more than one calibration. Discard any used buffer portions.
H. Finding: Values were reported that exceed the method specified accuracy of 0.1 units.

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#5406 Wilkes County Board of Education
Requirement: By careful use of a laboratory pH meter with good electrodes, a precision
of ±0.02 unit and an accuracy of ±0.05 unit can be achieved. However, ± 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, 4500 H+ B-2000. (6).
pH — Standard Methods, 4500 H'B-2000 (Aqueous)
Chlorine, Total Residual — Standard Methods, 4500 Cl G-2000 (Aqueous)
I. Finding: A post analysis check standard is not analyzed at the end of the sample route.
Requirement: When performing analyses away from the certified laboratory's primary
location, 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.0 or corrective actions must be taken.
Ref: NC WW/GW LC Approved Procedure for the Analysis of pH.
Requirement: When performing analyses away from the certified laboratory's primary
location, a post analysis calibration verification must be analyzed at the end of the run. 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 check standard must read within 10% of the true value of the post
analysis calibration verification check standard. If the obtained value is outside of the
±10% range, corrective action must be taken. Ref: NC WW/GW LC Approved Procedure
for the Analysis of Total Residual Chlorine.
Chlorine, Total Residual — Standard Methods, 4500 Cl G-2000 (Aqueous)
J. Finding: The laboratory is not using the currently assigned value for the Gel® check
standard.
Requirement: Immediately following curve verification:
1. Zero the instrument with the gel blank.
2. Read and record gel standard values.
3. Assign the obtained values as the true value.
The assigned values will be used for the next twelve months, or until a new curve
verification is performed. Ref: NC WW/GW LC Approved Procedure for the Analysis of
Total Residual Chlorine.
Comment: The laboratory's benchsheet was made several years ago and there is not an
electronic version that can be edited. The benchsheet had a preprinted value for the check
standard that was not changed from year to year. The laboratory was using the value 220
pg/L and the currently assigned value is 194 tag/L. An updated and editable electronic
benchsheet was prepared and emailed to the laboratory on July 28, 2016 where the
current check standard value can be entered along with the ±10% recovery acceptance
criterion.
K. Finding: Values less than the established reporting limit are being reported on the
Discharge Monitoring Report (DMR).

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#5406 Wilkes County Board of Education
Requirement: The concentrations of the calibration standards must bracket the
concentrations of the samples analyzed. One of the standards must have a concentration
equal to or below the lower reporting concentration for Total Residual Chlorine. The lower
reporting limit must be less than or equal to the permit limit. Ref: NC WW/GW LC
Approved Procedure for the Analysis of Total Residual Chlorine.
Comment: The lowest concentration standard analyzed during the July 19, 2016 curve
verification was 20 pg/L. Samples with concentrations less than 20 pg/L must be
reported as < 20 pg/L on the DMR.
Temperature — Standard Methods, 2550 B-2000 (Aqueous)
Comment: As the auditor stated on the day of the inspection, due to the new Approved
Procedure for the Analysis of Temperature, corrections are no longer applied to Temperature data
used for compliance reporting.
L. Finding: Documentation was not available to verify that the NIST thermometer used for
Temperature sensor verification is accurate within ± 0.5 °C.
Requirement: NIST traceable temperature measuring devices used for this verification
must have a stated accuracy of at least ± 0.5 °C. Document the verification data and keep
on file. Ref: NC WW/GW LC Approved Procedure for the Analysis of Temperature.
Comment: The temperature sensor verification for the DO and pH meters is performed by
a contract lab. The verification is documented but the only NIST information provided by
the contract lab is the thermometer ID.
Dissolved Oxygen — Standard Methods 4500 O G-2001 (Aqueous)
M. Finding: The DO meter calibration is not documented.
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Meter calibration and meter calibration time(s). Ref: NC WW/GW
LC Approved Procedure for the Analysis of Dissolved Oxygen.
Comment: Utilization of the benchsheets supplied by the auditor on July 28, 2016 via
email would fulfill this documentation requirement.
N. Finding: The laboratory benchsheet was lacking pertinent data: sample collection time,
analysis time.
Requirement: Data pertinent to each analysis must be maintained for five years.
Certified Data must consist of date collected, time collected, sample site, sample
collector, and sample analysis time. The field bench sheets must provide a space for the
signature or initials of the analyst, and proper units of measure for all analyses. Ref: 15A
NCAC 02H .0805 (g) (1).
Comment: The benchsheet currently in use does not have any spaces to enter
information about DO analysis, so there was no direct linkage to a sample collection or
analysis time. Utilization of the benchsheets supplied by the auditor on July 28, 2016 via
email would fulfill these documentation requirements.

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#5406 Wilkes County Board of Education
O. Finding: The DO meter identification is not documented.
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 Dissolved Oxygen.
Comment: Utilization of the benchsheets supplied by the auditor on July 28, 2016 via
email would fulfill this documentation requirement.
pH — Standard Methods, 4500 H+B-2000 (Aqueous)
Chlorine, Total Residual — Standard Methods, 4500 Cl G-2000 (Aqueous)
Temperature — Standard Methods, 2550 B-2000 (Aqueous)
P. Finding: Sample analysis time is not clearly documented.
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Date and time of sample collection; Date and time of sample
analysis - Alternatively, since EPA requires samples to be analyzed immediately, one
time may be documented for collection and analysis with the notation that samples are
measured in situ or immediately at the sampling site (i.e., immediately following
collection at a location as near to the collection point as possible). When this `one time'
option is used, state that the documented time is both collection and analysis time. Ref:
NC WW/GW LC Approved Procedure for the Analysis of Temperature.
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Date and time of sample analysis to verify the 15 minute holding
time is met. Alternatively, one time may be documented for collection and analysis
with the notation that samples are measured in situ or immediately at the sample site.
Ref: NC WW/GW LC Approved Procedure for the Analysis of pH and NC WW/GW LC
Approved Procedure for the Analysis of Total Residual Chlorine,
Comment: Utilization of the benchsheets supplied by the auditor on July 28, 2016 via
email would fulfill these documentation requirements.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North
Carolina Division of Water Resources. Data were reviewed for Mountain View (NPDES #
NC0046418) for January and March 2016, Trap Hill and Boomer Ferguson (NPDES #s
NC0046426 and NC0075515) for March 2016. The following errors were noted:

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#5406 Wilkes County Board of Education
Value on
Benchsheet
Date
Parameter
Location
Value on DMR
*Contract Lab
Data
Total Residual
Mountain
Reported on wrong date;
1/13/2016
Chlorine
View
g pg/L
1/11/2016
Effluent
3/17/2016
Total Residual
Boomer
20 pg/L
13 pg/L (Temperature
Chlorine
Effluent
result)
3/24/2016
TKN
Trap Hill
Effluent
*3.64 mg/L
5.90 mg/L JP result)
3/24/2016
NO3 + NO2
Trap Hill
Effluent
*28.0 mg/L
31.64 mg/L (TN result)
Mountain
3/24/2016
pH
View
6.90 S.U.
6.75 S.U.
Effluent
In order to avoid questions of legality, it is recommended that you contact the appropriate
Regional Office for guidance as to whether an amended DMR 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 Recommendation 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
respond to all Findings and include supporting documentation and implementation
dates for each corrective action.
Report prepared by: Beth Swanson Date: August 4, 2016
Report reviewed by: Tonja Springer Date: August 12, 2016