#5147_2016_1130_AO_FINAL

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5147
Laboratory Name:
Town of Pinetops WWTP
Inspection Type:
Field Municipal Maintenance
Inspector Name(s):
Anna Ostendorff and Gary Francies
Inspection Date:
November 30, 2016
Date Forwarded for Initial
Review:
January 12, 2017
Initial Review by:
Jason Smith
Date Initial Review
Completed:
January 17, 2017
Cover Letter to use:
❑ Insp. Initial ❑ Insp. Reg
❑Insp. No Finding ❑Insp. CP
®Corrected
❑Insp. Reg. Delay
Unit Supervisor/Chemist III:
Gary Francies
Date Received:
January 19, 2017
Date Forwarded to Admin.:
1/27/17
Date Mailed:
2/2/2017
Special Mailing Instructions:

Water Resources
ENVIRONMENTAL QUALITY
January 27, 2017
5147
Mr. Sidney Bridgers
Town of Pinetops WWTP
P.O. Drawer C
Pinetops, NC 27864
ROY COOPER
MICHEAL S. REGAN
S. JAY ZIMMERMAN
SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Bridgers:
, i,'r, ,.. ;;
Enclosed is a report for the inspection performed on November 30, 2016 by Anna Ostendorff and
myself. 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 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: Anna Ostendorff
Master file
Water Sciences Section
NC Wastewater/Groundwater Laboratory Certification Branch
1623 Mai! Service Center, Raleigh, North Carolina 27699-1623
Location: 4405 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone]
Internet: httpJ/deg.nc.gov/abouUdivisions/water•resources/water•resources-data/water•sciences•home-page/laboratorycertification•branch

LABORATORY NAME: Town of Pinetops WWTP
NPDES PERMIT #: NC0020435
ADDRESS: 500 Bruton Craft Ln
Pinetops, NC 27864
CERTIFICATE #: 5147
DATE OF INSPECTION: November 30, 2016
TYPE OF INSPECTION: Field Municipal Maintenance
AUDITOR(S): Anna Ostendorff and Gary Francies
LOCAL PERSON(S) CONTACTED: Sidney Bridgers
I. INTRODUCTION:
This laboratory was inspected by a representatives) 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 laboratory was well organized and documents were easily retrievable. 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.
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 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.
Requirements that reference 15A NCAC 2H .0805 (g) (2), stating "A record of instrument calibration
where applicable. must be filed in an orderly manner so as to be readily available for inspection upon
request.", are intended to be a requirement to document meter calibration. Use of this requirement is not
intended to imply that existing records are not adequately maintained unless the Finding speaks directly
to that.
Contracted analyses are performed by Environment 1 (Certification # 10).
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.

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*5147 Town of Pinetops WWTP
Ill. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
Comment: All original records were not on file. Measurements for Temperature, Dissolved Oxygen
and pH were recorded on a scrap piece of paper before transferring the results to the benchsheet. The
scrap piece of paper was then discarded. North Carolina Administrative Code, 15A NCAC 2H .0805 (g)
(1) states: Data pertinent to each analysis must be maintained for five years. Notification of acceptable
corrective action (i.e., a statement that the scrap piece of paper, properly dated and initialed, is
retained in a file with an effective date of December 1, 2016) was received by email on January 3, 2017
and clarified per a phone call on January 25, 2017. No further response is necessary for this
Finding.
Proficiency Testing
Comment: The laboratory was not analyzing PT samples in the same manner as environmental
samples. Additional quality control (known samples) was analyzed with PT samples. 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. 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. Notification of acceptable corrective action (i.e., a statement that
additional QC samples with known values will not be analyzed on the same day as the blind PT
samples beginning with the 2017 PT sample analysis) was received by email on January 3, 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 sample analysis results will be documented on the
benchsheet beginning with the 2017 PT sample analysis) was received by email on December 14,
2016. No further response is necessary for this Finding.
Comment: The preparation of PT samples was not documented. The Proficiency Testing
Requirements, February 20, 2012, Revision 1.2. document states: 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. Notification of acceptable
corrective action (i.e., a statement that the vendor's instructions would be signed, dated and retained
beginning with the 2017 PT sample analysis) was received by email on January 3, 2017. No further
response is necessary for this Finding.

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#5147 Town of Pinetops WWTP
pH — Standard Methods, 4500 H+ B-2000 (Aqueous)
Dissolved Oxygen — Standard Methods, 4500 O G-2001 (Aqueous)
Chlorine. Total Residual — Standard Methods, 4500 Cl G-2000 (Aqueous)
Temperature — Standard Methods, 2550 B-2000 (Aqueous)
Comment: The laboratory benchsheet was lacking pertinent information: facility name. The NC WW/GW
LC Approved Procedure for the Analysis of Total Residual Chlorine, NC WW/GW LC Approved
Procedure for the Analysis of Dissolved Oxygen, NC WW/GW LC Approved Procedure for the Analysis
of pH and NC WW/GW LC Approved Procedure for the Analysis of Temperature documents state: The
following must be documented in indelible ink whenever sample analysis is performed: Sampling site
including facility name and location, ID, etc. Notification of acceptable corrective action (i.e., a
statement that the benchsheet provided by the auditor, which includes documentation of the facility
name, was implemented effective January 2017) was received by email on January 3, 2017. No
further response is necessary for this Finding.
Comment: The laboratory benchsheet was lacking pertinent data: instrument identification. The NC
WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine, NC WW/GW LC
Approved Procedure for the Analysis of Dissolved Oxygen, NC WW/GW LC Approved Procedure for
the Analysis of pH and NC WW/GW LC Approved Procedure for the Analysis of Temperature
documents state: The following must be documented in indelible ink whenever sample analysis is
performed: Instrument Identification. Notification of acceptable corrective action (i.e., a statement that
the benchsheet provided by the auditor, which includes the identification of each instrument used for
each analysis, was implemented effective January 2017) was received by email on January 3, 2017.
No further response is necessary for this Finding.
pH — Standard Methods, 4500 H+ B-2000 (Aqueous)
Dissolved Oxygen — Standard Methods, 4500 O G-2001 (Aqueous)
Comment: The laboratory benchsheet was lacking pertinent data: units of measure. North Carolina
Administrative Code, 15A NCAC 2H .0805 (g) (1) states: 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. Notification of acceptable
corrective action (i.e., a statement that the benchsheet provided by the auditor, which includes all units
of measure, was implemented effective January 2017) was received by email on January 3, 2017. No
further response is necessary for this Finding.
pH — Standard Methods, 4500 H+ B-2000 (Aqueous)
Comment: The laboratory was not analyzing a check buffer on each analysis day. The benchsheet
had a column labeled "check buffer 7.0", but the buffer was actually being used as a third calibration
point. The NC WW/GW LC Approved Procedure for the Analysis of pH document states: The meter
must be calibrated with at least two buffers. In addition to the calibration standards, the meter must be
verified with a third calibration standard. The calibration and check standard buffer must bracket the
range of the samples being analyzed. The check standard buffer must read within a range of ± 0.1 pH
units to be acceptable. Notification of acceptable corrective action (i.e., a statement that the 7.0 buffer
is used to check the calibration with an effective date of December 14, 2016) was received by email on
December 14, 2016. No further response is necessary for this Finding.
Comment: The hold time for pH analysis was frequently exceeded. The analyst was under the
impression the hold time for pH was 20 minutes. Additionally, the analysis time recorded on the
benchsheet was the time the analysis was completed, rather than the time the analysis began. The

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#5147 Town of Pinetops WWTP
Code of Federal Regulations, Title 40, Part 136; Federal Register Vol. 77, No. 97, May 18, 2012; Table
II states: Hydrogen ion (pH) ... Analyze within 15 minutes. Notification of acceptable corrective action
(i.e., a statement that pH sample analysis begins within 15 minutes of collection with an effective date
of December 14, 2016) was received by email on December 14, 2016. No further response is
necessary for this Finding.
Comment: Values were reported that exceed the method specified accuracy of 0.1 units. Standard
Methods, 4500 H+ B-2000. (6) states: 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. Notification of
acceptable corrective action (i.e., a statement that pH values will be reported to 0.1 units beginning
with the December 2016 DMR) was received by email on January 3, 2017. No further response is
necessary for this Finding.
Comment: There was one instance observed where the facility voluntarily analyzed an additional
effluent sample but did not report the data as required. The North Carolina Administrative Code, 15A
NCAC 2B .0506 (b) (3) (J) states: 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. Notification of acceptable corrective action (i.e., a statement that all analyses performed on the
effluent will be reported on the DMR beginning with the December 2016 DMR) was received by email
on January 3, 2017. No further response is necessary for this Finding.
Dissolved Oxygen — Standard Methods, 4500 O G-2001 (Aqueous)
Comment: The meter was not being properly calibrated each day of use. The NC WW/GW LC
Approved Procedure for the Analysis of Dissolved Oxygen document states: Instruments are to be
calibrated according to the manufacturer's calibration procedure prior to analysis of samples each day
compliance monitoring is performed. Notification of acceptable corrective action (i.e., a statement that
the DO meter is properly calibrated each day of use with an effective date of December 14, 2016) was
received by email on December 14, 2016. No further response is necessary for this Finding.
Comment: The laboratory benchsheet was lacking pertinent information: Percent saturation. North
Carolina Administrative Code, 15A NCAC 2H .0805 (g) (1) states: Data pertinent to each analysis must
be maintained for five years. North Carolina Administrative Code, 15A NCAC 2H .0805 (g) (2) states: A
record of instrument calibration where applicable, must be filed in an orderly manner so as to be readily
available for inspection upon request. Notification of acceptable corrective action (i.e., a statement that
the benchsheet provided by the auditor, which includes a space to document the percent saturation,
was implemented effective January 2017) was received by email on January 3, 2017. No further
response is necessary for this Finding.
Chlorine, Total Residual — Standard Methods, 4500 Cl G-2000 (Aqueous)
Comment: The time of meter calibration was not documented. The NC WW/GW LC Approved
Procedure for the Analysis of Total Residual Chlorine document states: The following must be
documented in indelible ink whenever sample analysis is performed: Meter calibration and meter
calibration time(s). Notification of acceptable corrective action (i.e., a statement that the benchsheet
provided by the auditor, which includes a space to document the calibration time, was implemented
effective January 2017) was received by email on January 3, 2017. No further response is
necessary for this Finding.

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#5147 Town of Pinetops WWTP
Comment: The laboratory was not verifying the Gel® Standard every 12 months. The NC WW/GW LC
Approved Procedure for the Analysis of Total Residual Chlorine document states: Purchased "Gel -
type" or sealed liquid ampoule standards may be used for daily standard curve verification only. These
standards must be verified initially and every 12 months thereafter, with the standard curve. When this
is done, these standards may be used after the manufacturer's expiration date. It is only necessary to
verify the gel or sealed liquid standard which falls within the concentration range of the curve used to
measure sample concentrations. For example, if you are measuring samples against a low range
curve, a 200 lag/L standard would be verified, and not the 800 lag/L standard since the 800 lag/L
standard would be measured using a high range curve. Notification of acceptable corrective action
(i.e., a statement that the gel standard was assigned a true value and the true value will be reassigned
annually and documented with an effective date of December 14, 2016) was received by email on
December 14, 2016. No further response is necessary for this Finding.
Comment: The laboratory was not analyzing a reagent blank with the Total Residual Chlorine (TRC)
PT sample. The NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine
document states: Reagent Blank: A reagent blank (sometimes also referred to as a method blank) is
only required when laboratory water is used to make quality control and/or calibration standards. A
reagent blank is made from the same laboratory water source used to make quality control and/or
calibration standards with DPD. The concentration of reagent blanks must not exceed 50% of the
reporting limit (i.e., the lowest calibration or calibration verification standard concentration), unless
otherwise specified by the reference method, or corrective action must be taken. Notification of
acceptable corrective action (i.e., a statement that a reagent blank will be analyzed and the results
documented on the benchsheet when performing the annual TRC PT sample beginning with the 2017
PT sample analysis) was received by email on January 3, 2017. No further response is necessary
for this Finding.
Comment: Values less than the established reporting limit are being reported on the electronic
Discharge Monitoring Report (eDMR). The NC WW/GW LC Approved Procedure for the Analysis of
Total Residual Chlorine document states: 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. Notification of acceptable corrective action (i.e., a statement
that environmental samples with TRC values that measure below the reporting limit of 10 lag/L will be
reported as <10 lag/L beginning with the December 2016 DMR) was received by email on January 3,
2017. No further response is necessary for this Finding.
Temperature — Standard Methods, 2550 B-2000 (Aqueous)
Recommendation: It is recommended that all Temperature results reported for compliance
monitoring be rounded to whole numbers as recommended by the Precision in Discharge Monitoring
Reports document.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing maintained 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 February, May and July 2016.
The following errors were noted:

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#5147 Town of Pinetops VVVVTP
Date
Parameter
Location
Value on
Value on DMR
Benchsheet
7/18/2016
Temperature
Effluent
26.6°C
26.8°C
5/19/2016
Temperature
Effluent
18.1 °C
18.6°C
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:
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: Anna Ostendorff
Report reviewed by: Jason Smith
Date: January 12, 2017
Date: January 19, 2017

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