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HomeMy WebLinkAbout#5290_2016_1020_BS_FINALINSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5290 Laboratory Name: Hal Transou Inspection Type: Field Commercial Inspector Name(s): Beth Swanson Inspection Date: October 20, 2016 Date Report Completed: November 4, 2016 Date Forwarded to Reviewer: November 4, 2016 Reviewed by: Nick Jones Date Review Completed: November 7, 2016 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: November 7, 2016 Date Forwarded to Admin: 11/8/2016 Date Mailed: 11/10/2016 Special Mailing Instructions: Water Resources ENVIRONMENTAL QUALITY November 9, 2016 5290 Mr. Hal Transou 276 Laurelwood Dr. State Road, NC 28676 PAT MCCRORY DONALD R. VAN DER VAART S. JAY ZIMMERMAN SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Transou: Enclosed is a report for the inspection performed on October 20, 2016 by Beth Swanson. 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. 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, Gary Francies, Technical Assistance/Compliance Specialist Division of Water Resources Attachment cc: master file Beth Swanson Water Sciences Section NC Wastewater/Groundwater Laboratory Certification Branch 1623 Mail Service Center, Raleigh, North Carolina 27699-1623 Location: 4405 Reedy Creek Road, Raleigh, North Carolina 27607 Phone: 919-733-3908 ! FAX: 919-733-6241 Internet: http:/Ideg.ncgov/aboutldivisions/water-resources/water-resources-datalwater-sciences-home-page/laboratory-certification-branch LABORATORY NAME: Hal Transou NPDES PERMIT #: NCO038997 and NCO060691 ADDRESS: 276 Laurelwood Dr. State Road, NC 28676 CERTIFICATE #: 5290 DATE OF INSPECTION: October 20, 2016 TYPE OF INSPECTION: Field Commercial Maintenance AUDITOR(S): Beth Swanson LOCAL PERSON(S) CONTACTED: Hal Transou 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. II. GENERAL COMMENTS: Mr. Transou's files were readily available and complete. He was forthcoming and proactive in addressing issues that were 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 Pace Analytical Services, LLC - Eden, NC (Certification # 633). Current Quality Assurance Policies for Field Laboratories and Approved Procedure documents for the analysis of the facility's currently certified methods were provided at the time of the inspection. III. FINDINGS REQUIREMENTS COMMENTS AND RECOMMENDATIONS: Documentation Comment: No instances were found in the data reviewed, but the analyst noted that he was not aware of the location of qualifier codes on the contract data and as such has not been including them on the electronic Discharge Monitoring Report (eDMR) if there have been any. The analyst spoke with the contract lab and submitted a client report with data analyzed on October 31, 2016 which had a qualifier code and description circled for the BOD analysis that day to show he now understands where this information is found. He stated via phone conversation on November 3, 2016 that qualifiers will be documented in the comment section starting with the October 2016 eDMR. Comment: The laboratory did not retain documentation of buffers. The analyst transfers small amounts of the buffer used at the Yadkin Valley Sewer Authority (YVSA) WWTP (Certification #5043) lab to separate bottles for his daily use. These bottles are labeled with the lot number and expiration date of the buffer but linkage to the source buffer is lost when a new lot of buffer is put into use. The YVSA WWTP lab also did not retain all documentation of their buffers, so the buffer in use was not Page 2 #5290 Hal Transou traceable to the source. The 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. This information as well as the vendor and/or manufacturer, lot number, and expiration date must be retained for chemicals, reagents, standards and consumables used for a period of five years. Consumable materials such as pH buffers and lots of pre -made standards are included in this requirement. Notification of corrective action (i.e., a statement that the laboratory receipt log that is used by YVSA, which was previously submitted by that lab on October 31, 2016, will be retained in the laboratory's files) was received by email on November 3, 2016. No further response is necessary for this Finding. Comment: The analyst was not documenting the analysis of the PT samples in the same manner as environmental samples. The PT results were only written on the vendor's reporting page, but samples need to be associated with properly calibrated instruments and traceable to acceptable consumables. 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 the practice of documenting the result for the PT samples in the comments section of the laboratory benchsheet, which includes meter calibration and all other required information, will be implemented in 2017) was received by email on November 4, 2016. No further response is necessary for this Finding. Dissolved Oxygen — Standard Methods, 4500 O G-2001 (Aqueous) Comment: Meter calibration time was not documented. The NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen (DO) document states: The following must be documented in indelible ink whenever sample analysis is performed. Meter calibration and meter calibration time. Notification of acceptable corrective action (i.e., submission of an updated benchsheet that includes a space to enter the meter calibration time implemented on November 1, 2016 with a statement that the calibration time will be recorded when the facility is back in operation) was received by fax on November 3, 2016. No further response is necessary for this Finding. Comment: The benchsheet did not include units for the meter calibration value. 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., submission of an updated benchsheet implemented on November 1, 2016 that includes a note that DO values are mg/L) was received by fax on November 3, 2016. No further response is necessary for this Finding. Comment: The DO meter was not being calibrated properly. The analyst was not leaving the probe in the calibration chamber during calibration. The YSI Environmental, YSI 550A Dissolved Oxygen Instrument Operations Manual, Calibration in % Saturation, (1) states: Ensure that the sponge inside the instrument's calibration chamber is moist. Insert the probe into the calibration chamber. Notification of acceptable corrective action (i.e., a statement that the analyst is now calibrating the DO meter with the probe inside the chamber with a moist sponge and documentation that he reviewed the proper procedure on October 25, 2016) was received by email and fax on November 3, 2016. No further response is necessary for this Finding. Temperature — Standard Methods, 2550 B-2000 (Aqueous) Comment: The verification of the temperature measuring device used for compliance monitoring did not agree within ±0.5 °C of the National Institute of Standards and Technology (NIST) thermometer. The DO meter was being used for Temperature compliance monitoring, however, its temperature correction was -0.6 °C. The NC WW/GW LC Approved Procedure for the Analysis of Temperature document states: The thermometer/meter readings must be less than or equal to 0.5 °C from the NIST Page 3 #5290 Hal Transou IV. traceable temperature measuring device reading. If it is, no correction factor would be applied. If it is not, the thermometer/meter may not be used for compliance monitoring_ Notification of acceptable corrective action (i.e., documentation of the pH meter temperature sensor verification conducted on October 25, 21016 showing verification within +0.1 °C of the NIST traceable thermometer and a benchsheet with that meter ID documented for the Temperature results which was implemented on November 1, 2016) was received by email on October 28 and fax on November 3, 2016. No further response is necessary for this Finding. PH — Standard Methods, 4500 H+ B-2000 (Aqueous) Temperature — Standard Methods, 2650 B-2000 (Aqueous) Comment: Facility name and instrument identification were not consistently documented. The benchsheets in use had a space to enter both the facility name and instrument/thermometer identification but these items were not consistently filled out. The NC WW/GW LC Approved Procedure for the Analysis of Temperature and The NC WW/GW LC Approved Procedure for the Analysis of pH documents state: The following must be documented in indelible ink whenever sample analysis is performed. Sampling site including facility name and location ID etc Thermometer/instrument identification. Notification of acceptable corrective action (i.e., a completed updated benchsheet implemented October 27, 2016 with the facility names and meter IDs typed in) was received by fax on November 3, 2016. No further response is necessary for this Finding. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks, etc.) and client reports to eDMRs. Data were reviewed for MVP Group International (NPDES Permit #NC0060691) for August and May 2016 and Roaring Gap Club WWTP (NPDES Permit #NC0038997) for May and September 2016. No transcription errors were detected. The facility appears to be doing a good job of accurately transcribing data. Comment: Contract data that are less than the reporting limit are listed on the client report as "ND" (i.e., non -detect). The laboratory records these results on the eDMR as the contract lab's reporting limit without the "less than" (<) symbol. It was pointed out during the inspection that according to the Division of Water Resources NPDES Wastewater Permitting instructions on completing DMRs (http:fleiec�.nc.go�/about/divisions/wafer-resourc�s(water-resources-�errnits/wasfewater-branch/�pdes- wastewater/forms-documents), values of results which are less than a detectable limit should be reported in the daily cells using the "less than" symbol (<) and the detectable limit used during the testing (or the value with appropriate unit conversion). The analyst stated that starting on the October 2016 eDMR, any applicable "ND" values will be reported as "< reporting limit". When this is done, the following holds true: For calculation purposes only, recorded values of less than a detectable limit (< #.##) may be considered to equal zero (0) for all parameters except Fecal Coliform, for which values of "less than" may be considered to be equal to one (1). The analyst stated in an email on November 3, 2016, that he would report any non -detect values as "< reporting limit" beginning with the October 2016 eDMR. 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: Beth Swanson Date: November 4, 2016 Report reviewed by: Nick Jones Date: November 7, 2016