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
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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
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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