#5187_2017_0613_JS_FINAL

To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5187
Laboratory Name:
City of Hendersonville Water Plant
Inspection Type:
Field Municipal Maintenance
Inspector Name(s):
Jason Smith
Inspection Date:
June 13, 2017
Date Forwarded for Initial
Review:
July 18, 2017
Initial Review by:
Anna Ostendorff
Date Initial Review
Completed:
July 19, 2017
Cover Letter to use:
❑ Insp. Initial
❑Insp. No Finding
❑Corrected
❑ Insp. Reg
❑Insp. CP
®Insp. Reg. Delay
Unit Supervisor/Chemist III:
Todd Crawford
Date Received:
July 19, 2017
Date Forwarded to Admin.:
August 1, 2017
Date Mailed:
August 1, 2017
Special Mailing Instructions:

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i.NVIROIIl(il-.ti I Al. 0.t)m I I Y
August 1, 2017
5187
Mr. Keith Kirchner
City of Hendersonville Water Plant
305 Williams Street
Hendersonville, NC 28792
ROY COOPER
Governor
MICHEAL S. REGAN
Secre(m ,
S. JAY ZIMMERMAN
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Kirchner:
Direclor
Enclosed is a report for the inspection performed on June 13, 2017 by 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 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. 251.
Sincerely,
Todd Crawford
Technical Assistance & Compliance Specialist
NC WW/GW Laboratory Certification Branch
Attachment
cc: Dana Satterwhite, Jason Smith, Master File # 5187

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LABORATORY NAME: City of Hendersonville Water Plant
NPDES PERMIT : NCO042277
ADDRESS: 4139 Haywood Road
Mills River, NC 28759
CERTIFICATE #: 5187
DATE OF INSPECTION: June 13, 2017
TYPE OF INSPECTION: Field Municipal Maintenance
AUDITOR(S): Jason Smith
LOCAL PERSON(S) CONTACTED: Keith Kirchner
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.
II. GENERAL COMMENTS:
The facility is neat and well organized and has all the equipment necessary to perform the
analyses. Benchsheets are well designed, easy to follow and concise. Records are well organized
and easy to retrieve.
All required Proficiency Testing (PT) samples have been analyzed for the 2017 PT calendar year
and the graded results were 100% acceptable.
Contracted analyses are performed by Pace Analytical Services, LLC — Asheville, NC
(Certification #40) and the Hendersonville WWTP Laboratory (Certification #108).
Current Quality Assurance Policies for Field Laboratories and Approved Procedure documents
for the analysis of the facility's currently certified Field Parameters were provided at the time of
the inspection.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
A. Finding: Error corrections are not properly performed.
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

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#5187 City of Hendersonville Water Plant
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: The laboratory corrects errors with a single line and initials them, but does not
document the date of the change.
D. Finding: The laboratory needs to increase the traceability documentation of purchased
materials and reagents.
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 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 date opened and put into use is not documented for Total Residual
Chlorine (TRC) reagents.
C. Finding: The laboratory benchsheet was lacking pertinent data: Instrument Identification.
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 pH and NC WW/GW LC Approved Procedure for the
Analysis of Total Residual Chlorine.
Comment: Instrument identification is documented on the calibration logs.
D. Finding: The laboratory benchsheet and calibration logs were lacking pertinent data:
facility name.
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Sample site including facility name and location, ID, etc. 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.
E. Finding: The units of measure are not consistently documented.
Requirement: Data pertinent to each analysis must be maintained for five years. Certified
data must consist of date collected, time collected, samples site, sample collector, and
sample analysis time. The field bench sheets must provide a space for the signature of the
analyst, and proper units of measure for all analyses. Ref: 15A NCAC 2H .0805 (g) (1).
Comment: Units of measure for the pH buffers were not documented on the pH
calibration log or for the sample results documented on the benchsheet.
Proficiency Testing
F. Finding: The preparation of Proficiency Testing (PT) Samples for TRC analysis is not
documented.

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#5187 City of Hendersonville Water Plant
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
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 (e.g., pH), but it is recommended that the instructions be
maintained. Ref: Proficiency Testing Requirements, May 31, 2017, Revision 2.0.
Comment: Dating and initialing the instruction sheet for the preparation of the TRC PT
Sample would satisfy the documentation requirement.
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) and contract lab reports to electronic Discharge Monitoring Reports (eDMRs) submitted to
the North Carolina Division of Water Resources. Data were reviewed for the City of
Hendersonville Water Plant (NPDES permit # NC0042277) for January, February, March and
April 2017. The following error was noted:
Value on Denchsheet
Value on
Date
Parameter
Location
*Contract Lab Data
eDMR
1/4/17
Turbidity
Effluent
*1.9 NTU
2.2 NTU
To avoid questions of legality, it is recommended that you contact the appropriate Regional
Office for guidance as to whether an amended eDMR will be required. A copy of this report will
be made available to the Regional Office.
The facility was issued a permit effective July 1, 2011 which added Total Nitrogen (TN) as a
parameter to be monitored quarterly with no concentration limit. The laboratory has been reporting
Total Kjeldahl Nitrogen (TKN) as TN on the DMRs and eDMRs because the permit contained an
error in the Effluent Monitoring Requirements table, which states "TN = (NO2-N + NO3-N) = TKN".
This error has been corrected in the current permit, which was effective June 1, 2017, to state "TN
_ (NO2-N + NO3-N) + TKN". Since samples were not analyzed for NO2-N + NO3-N during this
time, amending the DMRs and eDMRs to correct this error is not possible. Please respond to
indicate that all future TN results will be properly reported.
V. CONCLUSIONS:
Correcting the above -cited Findings 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: Jason Smith Date: July 18, 2017
Report reviewed by: Anna Ostendorff Date: July 19, 2017

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