#5663_2017_0214_JS_FINAL

To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5663
Laboratory Name:
Tweetsie Railroad
Inspection Type:
Field Municipal Initial
Inspector Name(s):
Jason Smith
Inspection Date:
February 14, 2017
Date Forwarded for Initial
March 7, 2017
Review:
Initial Review by:
Tonja Springer
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 13, 2017
Date Forwarded to Admin.:
March 14, 2017
Date Mailed:
Special Mailing Instructions:

LNVIR0NHFHTAL. OUAI I'fY
March 14, 2017
5663
Mr. Brian Banner
Tweetsie Railroad
300 Tweetsie Lane
Blowing Rock, NC 28605
ROY COOPER
Governor
MICHEAL S. REGAN
Secreta,v
S. JAY ZIMMERMAN
SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Initial Inspection
Dear Mr. Banner:
Director
Enclosed is a report for the inspection performed on February 14, 2017 by Jason Smith. Since the
Finding(s) cited during the inspection were all corrected prior to the completion of the enclosed report, a
response is not required. The staff is commended for taking the initiative in correcting the Findings in
such a timely manner. 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 electronic mail, or if you have questions or need additional information,
please contact me at [phone] ext. 251.
Sincerely,
D mod'
Todd Crawford
Technical Assistance & Compliance Specialist
NC WW/GW Laboratory Certification Branch
Attachment
cc: Dana Satterwhite, Jason Smith, Master File 5663

On -Site Inspection Report
LABORATORY NAME: Tweetsie Railroad
NPDES PERMIT #: NCO032131
ADDRESS: 300 Tweetsie Lane
Blowing Rock, NC 28605
CERTIFICATE #: 5663
DATE OF INSPECTION: February 14, 2017
TYPE OF INSPECTION: Field Municipal Initial
AUDITOR(S): Jason Smith
LOCAL PERSON(S) CONTACTED: Brian Banner
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 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 documentation of purchased materials and
reagents. The NC WW/GW LC Quality Assurance Policies for Field Laboratories 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. Acceptable corrective action (i.e. benchsheets were updated to
include all required information) was performed by the laboratory and approved by the auditor
during the inspection. No further response is necessary for this Finding.

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#5663 Tweetsie Railroad
Comment: The laboratory benchsheet was lacking pertinent data: sample collection time, sample
analysis time, sample collector/analyst initials or signature, facility name 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: sampling
site including facility name and location, ID, etc. and instrument identification. Notification of
acceptable corrective action (i.e., an updated benchsheet which includes sample collection time,
sample analysis time, sample collector/analyst initials or signature, facility name and instrument
identification that will be implemented when the facility resumes operation in April 2017) was
received by fax on March 7, 2017. No further response is necessary for this Finding.
Proficiency Testing
Comment: The laboratory was not analyzing PT samples in the same manner as compliance
samples. The laboratory's common practice was to analyze a known standard along with the PT
sample as additional QC. Since this is not performed with all compliance samples, it is considered
additional QC. However, known samples are recommended when analyzing remedial PT samples
as part of the troubleshooting and corrective action process. The Proficiency Testing
Requirements, February 20, 2012, Revision 1.2. document states: 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. They shall not be
analyzed with additional quality control or replicated beyond what is routine for environmental
sample analysis. Notification of acceptable corrective action (i.e., a statement that a known
sample will not be analyzed with PT samples beginning in 2017) was received by fax on February
20, 2017. No further response is necessary for this Finding.
Comment: The laboratory was not documenting PT sample analyses in the same manner as
environmental samples. The Proficiency Testing Requirements, February 20, 2012, Revision 1.2.
document states: All PT sample analyses must be recorded in the daily analysis records as for
any environmental sample. This serves as the permanent laboratory record. Notification of
acceptable corrective action (i.e., a statement that PT analyses will be documented on the
benchsheet beginning in 2017) was received by fax on February 20, 2017. No further response
is necessary for this Finding.
Chlorine, Total Residual — Standard Methods, 4500 CI G-2000 (Aqueous)
Comment: The laboratory was not analyzing a check standard each analysis day. The NC
WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine document states:
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. Notification of
acceptable corrective action [i.e., a statement that a check standard (i.e., gel standard) will be
analyzed each analysis day beginning when the facility resumes operation in April 2017] was
received by fax on February 20, 2017. No further response is necessary for this Finding.

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#5663 Tweetsie Railroad
Comment: The incorrect units of measure (i.e., mg/L) were documented on the benchsheet.
North Carolina Administrative Code, 15A NCAC 2H .0805(g) (1) states: North Carolina
Administrative Code, 15A NCAC 2H .0805 (g) (1) states: The field benchsheets must provide a
space for the signature or initials of the analyst, and proper units of measure for all analyses.
Notification of acceptable corrective action [i.e., an updated benchsheet which includes proper
units of measure (i.e., pg/L) for Total Residual Chlorine that will be implemented when the facility
resumes operation in April 2017] was received by fax on March 7, 2017. No further response is
necessary for this Finding.
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 Tweetsie Railroad (NPDES
permit #NC0032131) for June, October and November, 2016. No transcription errors were
detected. The facility appears to be doing a good job of accurately transcribing data.
V. CONCLUSIONS:
All Findings noted during the inspection were adequately addressed prior to the completion of
this report. The inspector would like to thank the staff for its assistance during the inspection and
data review process. No response is required.
Report prepared by: Jason Smith Date: March 7, 2017
Report reviewed by: Tonja Springer Date: March 10, 2017

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