#5657_2017_0214_JS_FINAL

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5657
Laboratory Name:
Watauga County Board of Education
Inspection Type:
Field Municipal Initial
Inspector Name(s):
Jason Smith
Inspection Date:
February 14, 2017
Date Forwarded for Initial
March 10, 2017
Review:
Initial Review by:
Anna Ostendorff
Date Initial Review
March 10, 2017
Completed:
® Insp. Initial
❑ Insp. Reg
Cover Letter to use:
❑Insp. No Finding
❑Corrected
❑Insp. CP
❑Insp. Reg. Delay
(to use: rt click, properties, check)
Unit Supervisor/Chemist III:
Todd Crawford
Date Received:
March 10, 2017
Date Forwarded to Admin.:
March 22, 2017
Date Mailed:
March 24, 2017
Special Mailing Instructions:

Water Resources
LN V di20 NM LN i AL QUALM
March 23, 2017
5657
Mr. Bob Auton
Watauga County Board of Education
P.O. Box 1790
Boone, NC 28607
ROY COOPER
MICHEAL S. REGAN
S. JAY ZIMMERMAN
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Bob Auton:
Enclosed is a report for the inspection performed on February 14, 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 5657

LABORATORY NAME: Watauga County Board of Education
NPDES PERMIT #: NC0066991, NC0067024 and NC0067016
ADDRESS: 251 Pioneer Trail
Boone, NC 28607
CERTIFICATE #: 5657
DATE OF INSPECTION: February 14, 2017
TYPE OF INSPECTION: Field Municipal Initial
AUDITOR(S): Jason Smith
LOCAL PERSON(S) CONTACTED: Eric Bolick
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 facility has all the equipment necessary to perform the analyses. The laboratory analyst was
very forthcoming and receptive to implementing the necessary changes in response to the items
found during the inspection.
All required Proficiency Testing (PT) samples have been analyzed for the 2016 PT calendar year
and the graded results were 100% acceptable.
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 Field Parameters were provided at the time of
the inspection.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
Comment: The laboratory needed to increase the documentation of purchased materials and
reagents. The NC WW/GW LC Quality Assurance Policies for Field Laboratories document
states: 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. Consumable materials such as pH buffers and lots of pre -made standards
are included in this requirement. Notification of acceptable corrective action (i.e., the traceability
log provided by the inspector was put into use on March 9, 2017) was received by email on March
10, 2017. No further response is necessary for this Finding.

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#5657 Watauga County Board of Education
Comment: The laboratory benchsheet was lacking pertinent data: sample collection time, sample
analysis time, units of measure and instrument identification. North Carolina Administrative Code,
15A NCAC 2H .0805 (g) (1) states: 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. The
NC WW/GW LC Approved Procedure for the Field Analysis of Temperature, NC WW/GW LC
Approved Procedure for the Field Analysis of pH, NC WW/GW LC Approved Procedure for the
Field Analysis of Dissolved Oxygen and NC WW/GW LC Approved Procedure for the Field
Analysis of Total Residual Chlorine state: The following must be documented in indelible ink
whenever sample analysis is performed: instrument identification. Notification of acceptable
corrective action (i.e., an updated benchsheet including sample collection time, sample analysis
time, units of measure and instrument identification with an implementation date of March 13,
2017) was received by email on March 10, 2017. No further response is necessary for this
Finding.
Proficiency Testing
A. Finding: The laboratory is not analyzing PT samples in the same manner as compliance
samples.
Requirement: Laboratories shall conduct proficiency tests in accordance with their
routine testing, calibration and reporting procedures, unless otherwise specified in the
instructions supplied by the PT 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 and
preparatory techniques such as digestions, distillations and extractions. They shall not
be analyzed with additional quality control or replicated beyond what is routine for
environmental sample analysis. Results from multiple analyses (when this is the routine
procedure) must be calculated in the same manner as routine environmental samples.
Ref: Proficiency Testing Requirements, February 20, 2012, Revision 1.2.
Comment: Additional QC (i.e., sample with a known value) was analyzed with PT
samples.
Comment: Corrective -action PTs, that are provided with the true values in a sealed
envelope, are not considered PTs and do not meet the PT requirements outlined in 15A
NCAC 2H .0800. In general, laboratories must not analyze PTs with known
concentrations along with PTs with unknown concentrations, as this is not the routine
testing protocol for environmental samples. This is not to say that they cannot be used
for troubleshooting purposes before analyzing a remedial PT. This would be considered
part of the corrective action plan.
B. 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.

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#5657 Watauga County Board of Education
Chlorine, Total Residual — Standard Methods, 4500 Cl G-2000 (Aqueous)
C. Finding: A check standard (e.g., gel standard) is not analyzed each analysis day.
Requirement: When a five -standard annual standard curve verification is used, the
laboratory must check the calibration curve each analysis day. To do this, the laboratory
must analyze a calibration blank to zero the instrument and analyze a check standard
each day that samples are analyzed. The value obtained for the check standard must read
within 10% of the true value of the 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.
Dissolved Oxygen — Standard Methods, 4500 O G-2001 (Aqueous)
Comment: The salinity and elevation used for meter calibration was not documented. The NC
WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen states: The laboratory
must document each time that a calibration is performed. Calibration documentation must include
the following, where applicable to the instrument used and the type of calibration performed:
elevation, temperature, barometric pressure (in mmHg), salinity, slope, or %efficiency. Simply
recording a final reading (in mg/L) for instruments that auto calibrate (e.g., LDO sensors and
Membrane Electrodes that AUTOCAL) is also acceptable. Notification of acceptable corrective
action (i.e., an updated benchsheet including calibration elevation and salinity with an
implementation date of March 16, 2017) was received by email on March 16, 2017. No further
response is necessary for this Finding.
pH — Standard Methods, 4500 H+ B-2000 (Aqueous)
D. Finding: The meter is not verified after calibration.
Requirement: The meter must be calibrated with at least two buffers. In addition to the
calibration buffers, the meter calibration must be verified with a third standard buffer
solution. 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.
Temperature — Standard Methods, 2550 B-2000 (Aqueous)
E. Finding: The stated accuracy of the NIST traceable thermometer used to verify the meter
used to measure temperature for compliance monitoring was not at least ± 0.5 °C.
Requirement: Any temperature measuring device, used to measure temperature for
compliance monitoring, must be verified against a National Institute of Standards and
Technology (NIST) traceable temperature measuring device prior to initial use and re -
verified at least every 12 months and any time the instrument is serviced. NIST traceable
temperature measuring devices used for this verification must have a stated accuracy of at
least ± 0.5 °C. Ref: NC WW/GW LC Approved Procedure for the Field Analysis of
Temperature.
Comment: The analyst is currently checking the meter against the NIST traceable
thermometer daily. This is only required to be performed once every twelve months and
may be performed by the contract laboratory.

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#5657 Watauga County Board of Education
Dissolved Oxygen — Standard Methods, 4500 O G-2001 (Aqueous)
pH — Standard Methods, 4500 H+ B-2000 (Aqueous)
F. Finding: The instruments are not being calibrated prior to analysis of samples each day
compliance monitoring is performed.
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 Field Analysis of Dissolved Oxygen and NC
WW/GW LC Approved Procedure for the Field Analysis of pH.
Comment: The analyst calibrated the meters after completing work at all facilities thinking
that the calibration would be acceptable for use the next day.
pH — Standard Methods, 4500 H+ B-2000 (Aqueous)
Temperature — Standard Methods, 2550 B-2000 (Aqueous)
G. Finding: The analyst occasionally voluntarily analyzes effluent samples more frequently
than the permits require, but does not report all the data.
Requirement: The results of all tests on the characteristics of the effluent, including but
not limited to NPDES permit monitoring requirements, shall be reported on the monthly
report forms. Ref: 15A NCAC 2B .0506 (b) (3) (J).
Comment: Process control samples collected upstream of the final effluent are not
required to be reported.
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 Parkway Elementary (NPDES
permit #NC0067016) for May 2016, Valle Crucis Elementary (NPDES permit #NC0067024) for
July 2016 and Bethel Elementary (NPDES permit #NC0066991) for October 2016. The
following errors were noted:
Date
Parameter
Location
Value on
Value on DMR
Benchsheet
7/11/2016
Temperature
NC0067024
No Value Recorded
26 °C
Effluent
7/12/2016
Temperature
NC0067024
26 °C
No Value Reported
Effluent
7/18/2016
pH
NC0067024
No Value Recorded
6.8 S.U.
Effluent
7/18/2016
Temperature
NC0067024
No Value Recorded
18 °C
Effluent
7/19/2016
pH
NC0067024
6.8 S.U.
No Value Reported
Effluent

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#5657 Watauga County Board of Education
7/19/2016
Temperature
NC0067024
18 °C
No Value Reported
Effluent
Recommendation: The errors listed in the table above are transposition errors where data was
reported on the incorrect date and are not intended to imply falsification of data. It is
recommended that a process of peer review be initiated in order to reduce the frequency of errors.
It is also 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: Jason Smith Date: March 10, 2017
Report reviewed by: Anna Ostendorff Date: March 10, 2017