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NC Department of Environmental Quality | Division of Water Resources | Laboratory Certification Branch
4405 Reedy Creek Road | 1623 Mail Service Center | Raleigh, North Carolina 27699-1623
919-733-3908
April 4, 2022
5127
Mr. Trevor C. McMinn
TREVCO
2020 Howard Gap Road
Hendersonville, NC 28792
Subject: North Carolina Wastewater/Groundwater Laboratory Certification Branch (NC
WW/GW LCB) Maintenance Inspection
Dear Mr. McMinn:
Enclosed is a report for the inspection performed on March 2, 2022 by Jason Smith. Where
Finding(s) are cited in this report, a response is required. Within thirty days, 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 02H .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 have questions or need additional information, please contact me at (919) 733-
3908 ext. 251.
Sincerely,
Anna Ostendorff
Technical Assistance & Compliance Specialist
Division of Water Resources
Attachment
cc: Todd Crawford, Jason Smith, Master File #5127
On-Site Inspection Report
LABORATORY NAME: Trevco
NPDES PERMIT #: NC0086223 and NC0028975
ADDRESS: 2020 Howard Gap Road
Hendersonville, NC 28792
CERTIFICATE #: 5127
DATE OF INSPECTION: March 2, 2022
TYPE OF INSPECTION: Field Commercial Maintenance
AUDITOR(S): Jason Smith
LOCAL PERSON(S) CONTACTED:
Trevor McMinn and Heather Garren
I. INTRODUCTION:
This laboratory was inspected by a representative of the North Carolina Wastewater/Groundwater
Laboratory Certification Branch (NC WW/GW LCB) to verify its compliance with the requirements of 15A
NCAC 02H .0800 for the analysis of compliance monitoring samples.
II. GENERAL COMMENTS:
The facility is neat and well organized and has all the equipment necessary to perform the analyses.
Staff was forthcoming and responded well to suggestions from the auditor.
All required Proficiency Testing (PT) Samples have been analyzed for the 2022 PT Calendar Year and the
graded results were 100% acceptable.
The laboratory is reminded that any time changes are made to laboratory procedures, QA/SOP
document(s) must be updated and relevant staff retrained. Staff must acknowledge that they have read
and understand the changes as part of the documented training program. The same requirements apply
when changes are made in response to Findings, Recommendations or Comments listed in this report, to
ensure the methods are being performed as stated, references to methods are accurate, and the QA
and/or SOP document(s) is in agreement with each approved practice, test, analysis, measurement,
monitoring procedure or regulatory requirement being used in the laboratory. In some instances, the
laboratory may need to create an SOP to document how new functions or policies will be implemented.
Revisions to the SOPs, based on the Findings, Comments and Recommendations within this
report must be submitted to this office by October 1, 2022.
The laboratory is also reminded that SOPs are intended to describe procedures exactly as they are to be
performed. Use of the word “should” is not appropriate when describing requirements (e.g., Quality Control
(QC) frequency, acceptance criteria, etc.). Evaluate all SOPs for the proper use of the word “should”.
Contracted analyses are performed by Environmental Testing Services (Certification #600).
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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 shall 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; instead the correction shall be written adjacent to the
error. The correction shall be initialed by the responsible individual and the date of change
documented. Ref: 15A NCAC 02H .0805 (g) (1).
Comment: Error corrections are not dated or initialed.
B. Finding: The laboratory is not documenting all traceability information for purchased
materials, reagents and standards.
Requirement: 15A NCAC 02H .0805 (a)(7)(K) and (g)(7) requires laboratories to have a
documented system of traceability for the purchase, preparation, and use of all chemicals,
reagents, standards, and consumables. That system must include documentation of the
following information: Date received, Date Opened (in use), Vendor, Lot Number, and
Expiration Date (where specified). A system (e.g., traceable identifiers) must be in place
that links standard/reagent preparation information to analytical batches in which the
solutions are used. Documentation of solution preparation must include the analyst’s
initials, date of preparation, the volume or weight of standard(s) used, the solvent and final
volume of the solution. This information as well as the vendor and/or manufacturer, lot
number, and expiration date must be retained for primary standards, chemicals, reagents,
and materials used for a period of five years. Consumable materials such as pH buffers,
lots of pre-made standards and/or media, solids and bacteria filters, etc. are included in this
requirement. Ref: NC WW/GW LCB Traceability Documentation Requirements for
Chemicals, Reagents, Standards and Consumables Policy.
Comment: The date received is not documented.
C. Finding: Chemical containers are not dated when received and when opened.
Requirement: Chemical containers shall be dated when received and when opened. Ref:
15A NCAC 02H .0805 (g) (7).
D. Finding: The laboratory benchsheet is lacking required documentation: the instrument
identification.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses and shall consist of: the instrument
identification. Each item shall be recorded each time samples are analyzed. Analyses shall
conform to methodologies found in Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H
.0805 (g) (2) (C).
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E. Finding: The laboratory is not documenting the salinity value used to calibrate the
Dissolved Oxygen (DO) meter.
Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule.
Ref: 15A NCAC 02H .0805 (g) (4).
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Calibration variables (temperature, elevation or barometric pressure
[in mmHg], and salinity). Ref: NC WW/GW LCB Approved Procedure for the Analysis of
Dissolved Oxygen (DO).
F. Finding: The DO calibration log incorrectly labels the percent saturation as percent slope.
Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule.
Ref: 15A NCAC 02H .0805 (g) (4).
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Final calibration information (final DO reading in mg/L or %
saturation). Ref: NC WW/GW LCB Approved Procedure for the Analysis of Dissolved
Oxygen (DO).
G. Finding: The laboratory is not documenting the preparation of PT Samples.
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, however the instructions must be maintained. Ref: Proficiency Testing
Requirements, February 19, 2020, Revision 5, Section 3.6.
Comment: Dating and initialing the instruction sheet for each prepared PT Sample would
satisfy the documentation requirement.
Comment: The laboratory has their contract laboratory prepare the Total Residual Chlorine
PT for analysis. This requirement has been explained to the contract laboratory for future
PT sample preparation.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks, etc.)
and contract laboratory reports to Discharge Monitoring Reports submitted to the North Carolina
Division of Water Resources. Data were reviewed for Adventure Village (NPDES permit # NC0086223)
and the Saluda WWTP (NPDES permit # NC0028975) for January, May and July 2021. The following
errors were noted:
Date Parameter Location Value on
Benchsheet Value on DMR
1/26/2021 pH Adventure Village
Effluent 6.7 S.U. 6.1 S.U.
7/7/2021 Total Residual
Chlorine
Adventure Village
Effluent 40 µg/L 45 µg/L
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7/16/2021 Temperature Adventure Village
Effluent 22 °C 26 °C
To avoid questions of legality, it is recommended that you contact the appropriate Regional Office for
guidance as to whether an amended DMR(s) will be required. A copy of this report will be made
available to the Regional Office.
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, implementation dates and steps taken to prevent recurrence for each corrective
action.
Report prepared by: Jason Smith Date: March 14, 2022
Report reviewed by: Tonja Springer Date: March 14, 2022
Certificate Number:5127
Effective Date:1/1/2022
Expiration Date:12/31/2022
Lab Name:TREVCO
Address:2020 Howard Gap Road
Hendersonville, NC 28792-
North Carolina Wastewater/Groundwater Laboratory Certification
Certified Parameters Listing
Date of Last Amendment:10/26/2021
The above named laboratory, having duly met the requirements of 15A NCAC 2H.0800, is hereby certified for the measurement of the parameters listed below.
CERTIFIED PARAMETERS
INORGANIC
CHLORINE, TOTAL RESIDUAL
SM 4500 Cl G-2011 (Aqueous)
DISSOLVED OXYGEN
SM 4500 O G-2016 (Aqueous)
pH
SM 4500 H+B-2011 (Aqueous)
TEMPERATURE
SM 2550 B-2010 (Aqueous)
This certification requires maintance of an acceptable quality assurance program, use of approved methodology, and satisfactory performance on evaluation samples. Laboratories are subject to civil penalties and/or decertification for infractions
as set forth in 15A NCAC 2H.0807.