HomeMy WebLinkAbout#5639_2018_0315_BS_MC_FINALTo be attached to all inspection reports in-house only.
Laboratory Cert. #:
5639
Laboratory Name:
Shealy Environmental Services, Inc.
Inspection Type:
Field Commercial Maintenance
Inspector Name(s):
Beth Swanson, Michael Cumbus
Inspection Date:
March 15, 2018
Date Forwarded for Initial
Review:
March 27, 2018
Initial Review by:
Anna Ostendorff
Date Initial Review
Completed: .
March 28, 2018
Cover Letter to use:
❑ Insp. Initial ® Insp. Reg
❑Insp. No Finding ❑Insp. CP
❑Corrected
❑Insp. Reg. Delay
Unit Supervisor/Chemist III:
Beth Swanson
Date Received:
March 29, 2018
Date Forwarded to Admin.:
April 2, 2018
Date Mailed:
April 3, 2018
Special Mailing Instructions:
April 3, 2018
5639
Ms. Wendy Plessinger
Shealy Environmental Services Inc.
106 Vantage Point Dr
West Columbia, SC 29172
ROY COOPER
MICHAEL S. REGAN
Se
LINDA CULPEPPER
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Ms. Plessinger:
Enclosed is a report for the inspection performed on March 15, 2018 by Michael Cumbus. 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 (919) 733-3908 ext. 259.
Sincerely,
?J
Beth Swanson
Technical Assistance & Compliance Specialist
Division of Water Resources
Attachment
cc: Dana Satterwhite, Michael Cumbus, Masterfile #5639
_=•:1 •'
CERTIFICATE :
W Me
Shealy Environmental Services, Inc
228 Westinghouse Blvd., Suite 101
Charlotte, NC 28273
5369
March 15, 2018
Field Commercial Maintenance
Beth Swanson and Michael Cumbus
LOCAL PERSON(S) CONTACTED: Stephanie Atkins and Cal Easter
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.
II. GENERAL COMMENTS:
Records are well organized and easy to retrieve. Staff were forthcoming and seemed eager to
adopt necessary changes. The Findings cited are mainly documentation -related in order to bolster
the laboratory data's legal defensibility.
All required Proficiency Testing (PT) Samples have been analyzed for the 2018 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.
Contracted analyses are performed by Shealy Environmental Services, Inc. (Cert #329).
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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#5639 Shealy Environmental Services, Inc.
Documentation
A. Finding: The laboratory needs to increase the traceability of documentation of purchased
materials and reagents.
Requirement: 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 (where specified). 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 LC Policy.
Comment: The laboratory is transferring pH buffers from the parent bottles in Shealy
Environmental's main laboratory into smaller containers for use at the field location. All
required traceability information is written on the container except for the Date Opened.
B. Finding: The laboratory benchsheet was lacking pertinent data: Time of sample analysis.
Requirement: 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. Ref: 15A NCAC 2H .0805 (g) (1).
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Date and time of sample analysis. Ref: 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.
Comment: The benchsheet only documents the sample collection date and time for
Dissolved Oxygen (DO), Temperature and pH. Most analyses are taken in situ, but there is
no notation of this or a separate time for sample analysis.
C. Finding: Documentation of the calibration variables for the DO meter does not include all
pertinent data.
Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A
NCAC 2H .0805 (g) (1).
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: calibration variables (elevation, temperature, barometric pressure [in
mmHg], salinity). Ref: NC WW/GW LC Approved Procedure for the Analysis of Dissolved
Oxygen.
Comment: The laboratory documents temperature during meter calibration.
D. Finding: The laboratory benchsheet was lacking pertinent data: Units of measure.
Requirement: 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
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#5639 Shealy Environmental Services, Inc.
signature or initials 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: Units of measure. Ref: NC WW/GW LC Approved Procedure for the
Analysis of Dissolved Oxygen, NC WW/GW LC Approved Procedure for the Analysis of pH
and INC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine.
Comment: The laboratory recorded results for DO, pH and Total Residual Chlorine (TRC)
on the Chain of Custody (COC) as well as a field benchsheet. The COC form did not
contain units of measure for any parameter other than Temperature.
E. Finding: The laboratory benchsheet was lacking pertinent data for Temperature:
Instrument identification and method reference.
Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A
NCAC 21-1.0805 (g) (1).
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Instrument identification (serial number preferred) and method
reference. Ref: NC WW/GW LC Approved Procedure for the Analysis of Temperature.
Proficiency Testing
F. 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 (e.g., pH) but it is recommended that the instructions be maintained. Ref:
Proficiency Testing Requirements, May 31, 2018, Revision 2.0
Comment: Dating and initialing the instruction sheet for the preparation of the Total
Residual Chlorine PT Sample would satisfy the documentation requirement.
G. Finding: PT Samples have not been distributed among all analysts from year to year.
Requirement: Laboratories shall also ensure that, from year to year, PT samples are
equally distributed among personnel trained and qualified for the relevant tests and
instrument (when more than one instrument is used for routine Compliance Sample
analyses), that represents the routine operation of the work group at the time the PT
Sample analysis is conducted. Ref: Proficiency Testing Requirements, May 31, 2017,
Revision 2.0.
Chlorine, Total Residual — Standard Methods, 4500 CI G-2011 (Aqueous)
Comment: The laboratory verifies the factory set curve to a concentration of 15 pg/L, which is
low enough to meet all current clients' permit limits. The laboratory currently has clients who
request reporting limits that are higher than this value (i.e., 28 lag/L and 50 lag/L) so results are
reported to these clients as "<" the respective concentration. Reporting <50 lag/L does not allow
clients to demonstrate compliance if they have a permit limit.
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#5639 Shealy Environmental Services, Inc.
Recommendation: It is recommended that the meter zero blank and gel -type blanks be removed
from the daily benchsheet to avoid confusion.
Recommendation: It is recommended that subsequent calibration curve verifications be
performed using the same type of reagents as used for compliance sample testing. The most
recent calibration curve verification was performed using DPD powder reagents, while liquid
reagents are currently used for compliance sampling.
H. Finding: The laboratory did not verify the gel -type standard concentration before initial use.
Requirement: 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. Ref: NC WW/GW LC Approved
Procedure for the Analysis of Total Residual Chlorine.
Chlorine, Total Residual — Standard Methods, 4500 CI G-2011 (Aqueous)
pH — Standard Methods, 4500 H+ B-2011 (Aqueous)
I. Finding: The laboratory does not report results of all tests on the characteristics of the
effluent when duplicate sample analyses are performed.
Requirement: The results of all tests on the characteristics of the effluent, including but not
limited to NPDES monitoring requirements, shall be reported on the monthly report forms.
Ref 15A NCAC 2B .0506 (b) (3) (J).
Comment: The laboratory reports the first value as the sample result on client reports. For
pH, both values would need to be reported since pH cannot be averaged. For TRC, the
sample and duplicate values could be averaged and reported.
Comment: Duplicate analyses are not a required quality control element for Field
parameters.
Conductivity — EPA 120.1, Rev. 1982 (Aqueous)
Comment: No compliance data for the State of North Carolina has been analyzed in the past few
years.
Comment: The temperatures used during the last Automatic Temperature Compensator (ATC)
check were 23.6, 24.8 and 28.0 'C. When performing the next annual ATC check, the lowest
temperature must bracket the expected range of sample temperatures.
pH — Standard Methods, 4500 H+ B-2011 (Aqueous)
J. Finding: Values were reported that exceed the method specified accuracy of 0.1 units.
Requirement: 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. Ref: Standard Methods, 4500 H+ B-2011. (6).
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#5639 Shealy Environmental Services, Inc.
Temperature — Standard Methods, 2550 B-2010 (Aqueous)
Comment: The lowest temperature checked during the last temperature sensor verification was
22.2 °C. The two temperatures used to check the temperature -sensing probe on the pH meter
must bracket the expected compliance sample range. This is a new requirement since the last
temperature sensor check was performed.
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The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) and client reports. Data were reviewed for the following project numbers SG21021,
TB14063, SG28031, S105015, S127007, SK27013, SL18028, TA29032, TB14030, TB16060,
SL04039, SL27035, SL27015, TA10065. 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 Recommendations 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 Findings and include supporting documentation, implementation dates and steps
taken to prevent recurrence for each corrective action.
Report prepared by: Michael Cumbus Date: March 19, 2018
Report reviewed by: Anna Ostendorff Date: March 28, 2018
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