#5281 - 11 - 2011 - FINAL

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
December 5, 2011
5281
Mr. Tim Lancaster
Cleveland County Schools
866 Poplar Spring Church Rd.
Shelby, N.C. 28152
SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Lancaster:
Enclosed is a report for the inspection performed on November 9, 2011 by Chet Whiting. 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. 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 828-296-4677.
Sincerely,
✓'t,�3�-mac �-s�--t.,
Gary Francies
Unit Supervisor
Laboratory Section
CC: Chet Whiting
Master File
DENR DWQ Laboratory Section INC Wastewater/Groundwater Laboratory Certification Branch One
1623 Mail Service Center, Raleigh, North Carolina 27699-1623 NofthCarolina
Location: 4405 Reedy Creek Road. Raleigh, North Carolina 27607-6445
Phone: [phone] l FAX: [phone] vyaturallff
Internet: www.dwglab.org
An Equal Opportunity i Affirmative Action Employer Customer Service: 1.877-623-6748 www.ncwaterquality.org

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5281
Laboratory Name:
Cleveland County Schools
Inspection Type:
Field Maintenance
Inspector Name(s):
Chet Whiting
Inspection Date:
November 9, 2011
Date Report Completed:
November 29 2011
Date Forwarded to Reviewer: November 29, 2011
Reviewed by:
Todd Crawford
Date Review Completed:
November 30, 2011
Cover Letter to use: _
Insp. Initial X Insp. Reg. _ Insp. No Finding _ Insp. CID _Corrected
Unit Supervisor:
Gary Francies
Date Received:
11/30/2011
Date Forwarded to Linda:
12/2/2011
Date Mailed:s

On -Site Inspection Report
LABORATORY NAME:
NPDES PERMIT #
ADDRESS:
CERTIFICATE #:
110:2*672I0[+��x C�7rA
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LOCAL PERSON(S) CONTACTED:
I. INTRODUCTION:
Cleveland County Schools
NCO066397
866 Poplar Spring Church Rd.
Shelby, N.C. 28152
5281
November 9, 2011
Field Maintenance
Chet Whiting
Tim Lancaster
This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for
the analysis of environmental samples.
II. GENERAL COMMENTS:
There were significant improvements in organization and housekeeping. The facility is neat and well
organized and the equipment appeared to be clean and well maintained. Documents were well organized
and easy to retrieve.
Comment: Sample site was not documented. 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, 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. Notification of acceptable corrective action (i.e. notice of implementation of
a revised benchsheet provided by this office documenting the sample site) was received by e-mail
November 21, 2011. No further response is necessary for this finding.
Comment: Sample collection and analysis times were not adequately documented. 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, 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. Notification of
acceptable corrective action (i.e. notice of implementation of a revised benchsheet provided by this
office documenting collection and analysis time) was received by e-mail November 21, 2011 No
further response is necessary for this finding.
Comment: Units of measure were not documented. 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, sample site, sample collector, and sample analysis

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#5281 Cleveland Schools County Plant Operations
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. Notification of acceptable corrective action (i.e. notice of
implementation of a revised benchsheet provided by this office documenting units of measure) was
received by e-mail November 21, 2011. . No further response is necessary for this finding.
2H — Standard Methods, 20t" Edition, 4500 H+ B
Comment: There was no system in place to document Proficiency Testing (PT) samples in the same
manner as routine environmental samples. Quality Assurance Policies for Field Laboratories states:
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. Notification of acceptable corrective action (i.e. a
statement that performance samples will be documented on bench sheets the same as samples) was
received by e-mail on 10/19/2011. No further response is necessary for this finding.
A. Finding: Instances were observed where the pH calibration check exceeded ± 0.1 SU and no
corrective action was taken.
Requirement: For routine work, use a pH meter accurate and reproducible to 0.41 pH unit with a
range of 0 to 14, equipped with a temperature compensation device. Follow all manufacturers'
recommendations for the calibration of the meter each analysis day. In all cases, the meter
must be calibrated with at least two buffers. Calibrating with the pH 4 and pH 10 buffers meets
standard methods requirements and brackets the pH range for most monitoring (with the
exception of sludge) scenarios. The calibration; however, must bracket the range of the
samples being analyzed. In addition to the calibration standards, the meter must be verified with
a third calibration standard (e.g., pH 7 buffer). In order to meet the above -specified criteria, the
standard must read within a range of pH 6.9 to 7.1 to be acceptable. Ref: Technical Assistance
for Field Analysis of pH.
Comment: Possible corrective actions include: check the meter calibration procedure, refer to the
trouble shooting section in the instrument manual, and check the buffers. Even though the buffers
were within their expiration dates, the method and vendors point out that the expiration date is for
unopened buffers. Once buffers are opened the methods and manufacturers state that buffers
degrade and should be replaced in four weeks.
B. Finding: Data that does not meet all quality control requirements is not qualified on the
Discharge Monitoring Report (DMR).
Requirement: When quality control (QC) failures occur, the laboratory must attempt to
determine the source of the problem and must apply corrective action. Part of the corrective
action is notification to the end user. If data qualifiers are used to qualify samples not meeting
QC requirements, the data may not be useable for the intended purposes. It is the responsibility
of the laboratory to provide the client or end -user of the data with sufficient information to
determine the usability of the qualified data. Where applicable, a notation must be made on the
Discharge Monitoring Report (DMR) form, in the comment section or on a separate sheet
attached to the DMR form, when any required sample quality control does not meet specified
criteria and another sample cannot be obtained. Ref: Quality Assurance Policies for Field
Laboratories.

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#5281 Cleveland Schools County Plant Operations
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing field testing records and contract lab reports to Discharge
Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data for
NPDES# NCO066397 was reviewed for June and July, 2011. No transcription errors were detected.
The facility appears to be doing a good job of accurately transcribing data.
V. CONCLUSIONS:
Correcting the above -cited finding will help this lab to produce quality data and meet certification
requirements. The inspector would like to thank the staff for its assistance during the inspection and
data review process. Please respond to all findings.
Report prepared by: Chet Whiting Date: November 29, 2011
Report reviewed by: Todd Crawford Date: November 30, 2011