#5186_2018_0524_MC_FINAL

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To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5186
Laboratory Name:
Allvac - Monroe Plant
Inspection Type:
Field Industrial Maintenance
Inspector Name(s):
Michael Cumbus, Beth Swanson
Inspection Date:
May 24, 2018
Date Forwarded for Initial
Review:
May 30, 2018
Initial Review by:
Anna OstendorFf
Date Initial Review
Completed:
May 31, 2018
Cover Letter to use:
❑ Insp. Initial
❑Insp. No Finding
❑Corrected
® Insp. Reg
❑Insp. CP
❑Insp. Reg. Delay
Unit Supervisor/Chemist III:
Beth Swanson
Date Received:
June 5, 2018
Date Forwarded to Admin.:
June 8, 2018
Date Mailed:
June 11, 2018
Special Mailing Instructions:
MC- email copy to [e-mail]

ROY COOPER
6-OVe010,,
MICHAEL S. REGAN
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LINDA CULPEPPER
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June 8, 2018
5186
Mr. Joe Hinkle
Allvac - Monroe Plant
P.O. Box 5030
Monroe, NC 28110-
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Hinkle:
Enclosed is a report for the inspection performed on May 24, 2018 by Michael Cumbus and Beth
Swanson. 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. 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 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] ext. 259.
Sincerely,
9AL---
Beth Swanson
Technical Assistance & Compliance Specialist
Division of Water Resources
Attachment
cc: Michael Cumbus, Dana Satterwhite
NC Wastewater/Groundwater Laboratory Certification Branch
1623 Mail Sere Center, Raleigh, North Carolina 27699-1623
Location: 4405 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone]
Internet: http:I/dea.nc.ciovlabout/division slwater-resources/water-resources-data/water-sciences-home-paaellaboratory-certification- bran ch

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Allvac — Monroe Plant
NC0045993
ADDRESS. 2020-Ashcraft Ave
Monroe, NC 28110
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5186
May 24, 2018
Field Industrial Maintenance
Michael Cumbus and Beth Swanson
LOCAL PERSON(S) CONTACTED: Tommy Long, Joe Hinkle, James Moser and David Ethridge
INTRODUCTION:
This laboratory was inspected by 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.
IL GENERAL COMMENTS:
The facility is neat and well organized and has all the equipment necessary to perform the
analyses. Benchsheets are well designed and easy to follow. Records are well organized and easy
to retrieve. Staff were forthcoming and seemed eager to adopt necessary changes.
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.
Contracted analyses are performed by Pace Analytical Services, LLC — Huntersville (Certification
#12).
All required Proficiency Testing (PT) Samples have been analyzed for the 2018 PT Calendar Year
and the graded results were 100% acceptable.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:

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#5186 Allvac - Monroe Plant
Documentation
A: Finding: Error corrections are not properly performed.
Requirement: All documentation errors must 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. Write the correction adjacent to the error. The correction
must be initialed by the responsible individual and the date of change documented. All data
and log entries must be written in indelible ink. Pencil entries are not acceptable. Ref:
Quality Assurance Polices for Field Laboratories.
Comment: The laboratory was initialing error corrections and drawing a single line through
the errors but was not dating them.
B: Finding: The laboratory benchsheet was lacking pertinent data: permit number, instrument
identification, method reference, time of sample analysis, units of measure.
Requirement: 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. Ref: 15A NCAC 2H .0805 (g) (1).
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: permit number, method reference, units of measure, instrument
identification (serial number preferred) and time of sample analysis. Ref: NC WW/GW LC
Approved Procedure for the Analysis of pH and NC WW/GW LC Approved Procedure for
the Analysis of Temperature.
Comment: The laboratory benchsheet has the units of measure for the pH post -analysis
check listed as S.I. instead of S.U. All other units of measure were included and correct.
Comment: The laboratory incorrectly cites the method reference for pH on the benchsheet
as SM 4500 H+B, 18th ed. instead of SM 4500 H+B-2011.
Comment: The laboratory was recording one date and time for collection and analysis of
temperature. A notation on the benchsheet that samples are analyzed in situ would satisfy
the Certification requirement.
C. Finding: The laboratory benchsheet for pH was lacking pertinent data: true value of the
post -analysis check standard buffer.
Requirement: 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. Ref: 15A NCAC 2H .0805 (g) (1).
Requirement: The following must be documented in indelible ink whenever sample analysis
is performed: true value and value obtained for the post analysis calibration verification.
Ref: NC WW/GW LC Aooroved Procedure for the Analvsis of oH.
Proficiency Testing

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#5186 Allvac — Monroe Plant
D. Finding: Additional Quality Control (QC) beyond what is routine for Compliance Samples is
being analyzed with PT Samples.
Requirement: Laboratories are required to analyze an appropriate PT Sample by each
parameter method on the laboratory's Certified Parameters Listing (CPL). The same PT
Sample may be analyzed by one or more methods. Laboratories shall conduct the
analyses in accordance with their routine testing, calibration and reporting procedures,
unless otherwise specified in the instructions supplied by the Accredited PT Sample
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, preparatory techniques (e.g.,
digestions, distillations and extractions) and the same quality control acceptance criteria.
PT Samples shall not be analyzed with additional quality control. They are not to be
replicated beyond what is routine for Compliance Sample analysis. PT Sample results from
multiple analyses (when this is the routine procedure) must be calculated in the same
manner as routine Compliance Samples. Ref: Proficiency Testing Requirements, May 31,
2017, Revision 2.0.
Comment: The laboratory was analyzing an extra known Quality Control Sample with the
PT Sample.
Temperature — Standard Methods, 2550 B-2010 (Aqueous)
Comment: The laboratory is not performing the annual temperature -measuring device check
procedure correctly. The NC WW/GW LC Approved Procedure for the Analysis of Temperature
document states: To check a compliance temperature -measuring device, compare readings at two
temperatures that bracket the range of compliance samples routinely analyzed against a National
Institute of Standards and Technology (NIST) traceable temperature -measuring device and record
all four readings. The readings from both devices must agree within 0.5 °C. Acceptable corrective
action (i.e., the laboratory replaced the thermometer with a new thermometer (s/n: 170641111) with
a valid NIST certificate and an accuracy of at least ± 0.5°C and stated that a new traceable
thermometer, with a stated accuracy of ± 0.5°C will be put into use every 12 months to prevent
future recurrence) was performed by the laboratory and approved by the auditor during the
inspection. No further response is necessary for this Finding.
Recommendation: The laboratory is analyzing and reporting temperature to one decimal place. It
is recommended that the laboratory continue recording sample temperatures to one decimal place
and round to whole numbers for reporting purposes.
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 the Allvac — Monroe Plant
(NPDES permit #NC0045993) for November 2017 and January and April 2018. No transcription
errors were observed. The facility appears to be doing a good job of accurately transcribing
data.
V. CONCLUSIONS:
Correcting the above -cited findings and implementing the Recommendation will help this laboratory
to produce quality data and meet Certification requirements. The inspectors would like to thank the
staff for their assistance during the inspection and data review process. Please respond to all

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#5186 Allvac - Monroe Plant
Findings and include supporting documentation, implementation dates and steps taken to
prevent recurrence for each corrective action.
Report prepared by: Michael Cumbus Date: May 30, 2018
Report reviewed by: Anna Ostendorff Date: May 31, 2018

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