HomeMy WebLinkAbout#5043_2016_1020_BS_FINALINSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5043
Laboratory Name:
Yadkin Valley Sewer Authority (YVSA) UW TP
Inspection Type:
Field Maintenance
Inspector Name(s):
Beth Swanson
Inspection Date:
October 20, 2016
Date Report Completed:
November 8, 2016
Date Forwarded to Reviewer:
November 8, 2016
Reviewed by:
Anna Ostendorff
Date Review Completed:
November 9, 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 9, 2016
Date Forwarded to Admin: 11/10/16
Date Mailed: 11/14/16
Special Mailing Instructions:
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Water~ Resources
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November 14, 2016
5043
Mr. Hal Transou
Yadkin Valley Sewer Authority (YVSA) WWTP
211 Marion Road
Elkin, NC 28621
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:
)111 for
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: 919-733-39081 FAX; 919-733-6241
Internet: httw ldea.nc.gov/abouttdivisionslwater-resources/water-resources-data/water-sciences-home-page/laboratory-certification-branch
LABORATORY NAME: Yadkin Valley Sewer Authority (YVSA) WWTP
NPDES PERMIT #: NC0020567
ADDRESS: 211 Marion Rd.
Elkin, NC 28621
CERTIFICATE #: 5043
DATE OF INSPECTION: October 20, 2016
TYPE OF INSPECTION: Field Municipal 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.
GENERAL COMMENTS:
The facility's files were readily available and complete. The analysts were forthcoming and
proactive in addressing issues that were found during the inspection.
All required Proficiency Testing (PT) samples have been analyzed and the laboratory has fulfilled
its PT requirements for the 2016 PT calendar year.
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 Environment 1, Inc. (Certification # 10).
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: Error corrections were not properly performed. The Quality Assurance Policies for
Field Laboratories document states: All documentation errors must be corrected by drawing a
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#5043 Yadkin Valley Sewer Authority (YVSA) WWTP
single line through the error so that the original entry remains legible. Entries shall not be
obliterated by erasures or markings. Write the correction adjacent to the error. The correction
must be initialed by the responsible individual and the date of change documented. Notification of
acceptable corrective action (i.e., a section of the SOP detailing the proper method of error
correction with documentation showing that the analysts reviewed the pertinent section on
October 25, 2016 and a statement that an annual review of the SOPs will be instituted going
forward) was received by email on October 28 and November 8, 2016. No further response is
necessary for this Finding.
Comment: The lab was not transferring all information pertaining to qualified data to the
electronic Discharge Monitoring Report (eDMR). The qualifier language was entered into the
comments section, but there was no indication which sample/parameter the information was
referring to. The Quality Assurance Policies for Field Laboratories document states: Where
applicable, a notation must be made on the Discharge Monitoring Report (DMR) form, in the
comment section, when any required sample quality control does not meet specified criteria and
another sample cannot be obtained. Notification of acceptable corrective action (i.e., a statement
that the parameter affected will be included in the comment beginning with the October 2016
eDMR (or as soon as applicable) was received by email on October 31, 2016. No further
response is necessary for this Finding.
Comment: The laboratory was lacking some traceability information. The pH buffers were
recorded on the benchsheet and the date opened and date received were written on the bottles,
but the linkage between the two sets of information was lost once the bottles were discarded. No
traceability information was available for the Total Residual Chlorine (TRC) DPD powder. 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 acceptable corrective action (i.e., submission of a lab receipt log
containing all the required information which was filled out with the current pH buffers and DPD
powder and implemented on October 31, 2016. Additionally, a statement that the required
information to document traceability will be added to the facility's SOP by December 31, 2016
while instituting an annual review of said SOP.) was received by email on October 31 and
November 8, 2016. No further response is necessary for this Finding.
Proficiency Testin
Comment: The analyst was not documenting the preparation of the TRC PT. The Proficiency
Testing Requirements, February 20, 2012, Revision 1.2 document states: PT samples received
as ampules must be diluted according to the PT provider's instructions. The preparation of PT
samples must be documented in a traceable log or other traceable format. The diluted PT sample
becomes a routine environmental sample and is added to a routine sample batch for analysis.
Notification of acceptable corrective action (i.e., a statement that the practice of initialing and
dating the instruction sheet for the TRC PT sample will be implemented in 2017 and a copy of the
2016 PT instructions initialed and dated for demonstration) was received by email on October 31,
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
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#5043 Yadkin Valley Sewer Authority (YVSA) VWVfP
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 October 31,
2016. No further response is necessary for this Finding.
Dissolved Oxygen — Standard Methods, 4500 O G-2001 (Aqueous)
Comment: The Dissolved Oxygen (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., documentation showing
that the analysts reviewed the pertinent section of the DO SOP on October 25, 2016 which has
the correct calibration procedure and a statement that the practice was implemented going
forward from that date) was received by email on October 28 and November 10, 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 results, however, its 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
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, 2016 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 October 27, 2016. Also, a statement that the verification requirements for
thermometers/meters will be added to the facility's SOP by December 31, 2016 while instituting an
annual review of said SOP) was received by email on October 28, 31 and November 8, 2016. No
further response is necessary for this Finding.
Chlorine, Total Residual — Standard Methods, 4500 Cl G-2000 (Aqueous)
Comment: Values less than the established reporting limit were being reported on the eDMR.
The lowest concentration standard analyzed during the most recent curve verification was 15
pg/L. When the result was between 10 and 15 pg/L, the laboratory was reporting the actual
measured value from the instrument and for results less than 10 pg/L they were reporting <10
pg/L. The NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine
document states: The concentrations of the calibration standards must bracket the concentrations
of the samples analyzed. One of the standards must have a concentration equal to or below the
lower reporting concentration for Total Residual Chlorine. The lower reporting limit must be less
than or equal to the permit limit. Notification of acceptable corrective action (i.e., statements that
the current reporting limit (i.e., 15 pg/L) will be used starting on the October 2016 eDMR and the
lowest concentration standard used for the curve verification in subsequent years will be the
reporting limit, the directions for which will be added to the facility's SOP by December 31, 2016
while instituting an annual review of said SOP) was received by email on October 31, 2016. No
further response is necessary for this Finding.
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#5043 Yadkin Valley Sewer Authority (YVSA) WWTP
pH — Standard Methods, 4500 H+ B-2000 (Aqueous)
Dissolved Oxygen — Standard Methods, 4500 O G-2001 (Aqueous)
Comment: The benchsheet did not include all necessary units. Units for the pH calibration
buffers and check buffer and for the calibration value of the DO meter were not documented on
the benchsheet. 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 that was implemented October 27, 2016 which includes a note that all pH
units are S.U. and the DO meter calibration units are mg/L) was received by email on October 31,
2016. No further response is necessary for this Finding.
Dissolved Oxygen — Standard Methods, 4500 O G-2001 (Aqueous)
Temperature — Standard Methods, 2550 B-2000 (Aqueous)
pH — Standard Methods, 4500 H+ B-2000 (Aqueous)
Comment: Some pertinent data was absent from the original records. The analyst started using a
separate log book as the original record on October 18, 2016 for DO, Temperature and pH
analysis. Previously the original records for these parameters had not been retained after
transferring the data to the laboratory benchsheet. However, this log book did not label which
analysis each value was associated with, did not include units for pH and Temperature, analysts
initials or instrument IDs. North Carolina 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 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 the updated benchsheet
which was implemented on October 27, 2016 with a statement that only the printed benchsheet
will be used as the original record going forward) was received by email on October 31, 2016. No
further response is necessary for this Finding.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing records (e.g., laboratory benchsheets, logbooks, etc.)
and contract lab reports to electronic Discharge Monitoring Reports (eDMRs) submitted to the
North Carolina Division of Water Resources. Data were reviewed for Yadkin Valley Sewer
Authority WWTP (NPDES Permit #NC0020567) for March, May and August 2016. No
transcription errors were detected. The facility appears to be doing a good job of accurately
transcribing data.
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 8, 2016
Report reviewed by: Anna Ostendorff Date: November 8, 2016