HomeMy WebLinkAbout#5295_2016_0609_BS_FINAL11 Z61 ' e \ 2e
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5295
Laboratory Name:
Leonard Stogner
Inspection Type:
Field Maintenance
Inspector Name(s):
Beth Swanson
Inspection Date:
June 9, 2016
Date Report Completed:
June 15, 2016
Date Forwarded to Reviewer:
June 17, 2016
Reviewed by:
Anna Ostendorff
Date Review Completed:
June 20, 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: June 20, 2016
Date Forwarded to Admin: June 28, 2016
Date Mailed: June 28. 2016
Special Mailing Instructions:
Water Resources
ENVPRQNMEIN T AL QUALITY
June 29, 2016
5295
Mr. Leonard E. Stogner
30288 Bridge Rd
Mt. Pleasant, NC 28124
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. Stogner:
Enclosed is a report for the inspection performed on June 9, 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 bV
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: Beth Swanson
Masterfile
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: 919-733-39081FAX: 919-733-6241
Internet: http:lfdeg.nc.9GV1about/divisionslwater-resources/water-resources-datalwater-sciences-home- pageliaboratory-certification-branch
LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
INTRODUCTION:
• • � ' • 0
Leonard E. Stogner
NC0029246
30288 Bridge Rd
Mt. Pleasant, NC 28124
5295
June 9, 2016
Field Maintenance
Beth Swanson
Leonard Stogner
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. Stogner's records were filed in an orderly manner and easy to retrieve. He was very
forthcoming and very receptive to all necessary changes in response to the small number of items
discovered at 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 K & W Laboratories (Certification # 559).
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: Not all traceability information was being retained. The pH buffers are aliquots of a
larger bottle given to the facility by their contract lab. The bottles contain the vendor name, buffer
concentration, lot number and expiration date. The lot number and expiration date of the pH
buffers were documented on the calibration benchsheet. However, the date the aliquot was
received and put into use was not recorded, and the vendor information was lost upon discarding
the bottle. 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.
Page 2
#5295 Leonard E. Stogner
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., the certificates of analysis for the
current buffers and a statement that all certificates from this point forward will be obtained and
labeled with the date the aliquot was received) was received by email on 6/14/2016. No further
response is necessary for this Finding.
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
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.
Notification of acceptable corrective action (i.e., a statement that the practice of error correction
with a single line, date and initials would be implemented on 6/15/2016) was received by email on
6/17/2016. No further response is necessary for this Finding.
Comment: The laboratory is not documenting Proficiency Testing (PT) sample analyses in the
same manner as environmental samples. The Proficiency Testing Requirements 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 pH PT sample will be documented on the pH
calibration log in the same space as for effluent samples, but with a designation of the PT study
number to distinguish it from the effluent, with implementation beginning with the 2017 PT
sample) was received by email on 6/14/2016. No further response is necessary for this
Finding.
pH — Standard Methods, 4500 H+ B-2000 (Aqueous)
Dissolved Oxygen — Standard Methods, 4500 O G-2001 (Aqueous)
Temperature — Standard Methods, 2550 B-2000 (Aqueous)
Comment: The laboratory benchsheets were lacking pertinent data: Instrument identification.
The 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 documents state: The following must be documented in indelible
ink whenever sample analysis is performed: Instrument Identification. Notification of acceptable
corrective action (i.e., updated benchsheets including instrument identification with an
implementation date of 6/14/2016) was received by email on 6/14/2016. No further response is
necessary for this Finding.
Dissolved Oxygen — Standard Methods, 4500 O G-2001 (Aqueous)
Temperature — Standard Methods, 2550 B-2000 (Aqueous)
Comment: Sample analysis time was not clearly documented. There was only one time
documented on the benchsheet, with no statement that the sample was analyzed in situ or on site.
The NC WW/GW LC Approved Procedure for the Analysis of Temperature document states:
The following must be documented in indelible ink whenever sample analysis is performed:
Date and time of sample collection; Date and time of sample analysis - Alternatively, since EPA
requires samples to be analyzed immediately, one time may be documented for collection and
analysis with the notation that samples are measured in situ or immediately at the sampling site
(i.e., immediately following collection at a location as near to the collection point as possible).
When this `one time' option is used, state that the documented time is both collection and
Page 3
#5295 Leonard E. Stogner
analysis time. The NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen
document states: The following must be documented in indelible ink whenever sample analysis
is performed: Date and time of sample collection; Date and time of sample analysis to verify the
15 minute holding time is met. Alternatively, one time may be documented for collection and
analysis with the notation that samples are measured in situ or immediately at the sample site.
Notification of acceptable corrective action (i.e., updated benchsheets including a statement
that "all samples are in stream and instantaneous" with an implementation date of 6/14/2016)
was received by email on 6/14/2016. No further response is necessary for this Finding.
pH — Standard Methods, 4500 H+ B-2000 (Aqueous)
Comment: Values were reported that exceed the method specified accuracy of 0.1 units.
Standard Methods, 4500 H+ B-2000. (6) states: 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. Notification of acceptable corrective action (i.e., a statement that rounding
the pH result and reporting it to the nearest 0.1 units will be implemented on the June 2016 DMR,
or the month including the next flow) was received by email on 6/14/2016. No further response
is necessary for this Finding.
Temperature — Standard Methods, 2550 B-2000 (Aqueous)
Comment: Documentation was not available to verify that the NIST thermometer used for
Temperature sensor verification is accurate within ± 0.5 °C. The facility has the temperature
measuring devices verified annually by their contract lab. The verification process documents the
NIST thermometer's serial number, but does not include documentation of the accuracy of that
thermometer. The NC WW/GW LC Approved Procedure for the Analysis of Temperature
document states: NIST traceable temperature measuring devices used for this verification must
have a stated accuracy of at least± 0.5 °C. Document the verification data and keep on file.
Notification of acceptable corrective action (i.e., submitted documentation showing the NIST
thermometer used for verification in 2016 has accuracy within ± 0.5 °C in the range of sample
temperatures and a statement this documentation will be obtained for all future annual
verifications) was received by email on 6/14/2016. No further response is necessary for this
Finding.
Comment: As the auditor stated on the day of the inspection, due to the new Approved
Procedure for the Analysis of Temperature, corrections are no longer applied to Temperature data
used for compliance reporting.
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 Norfolk Southern Railway
Company- Linwood Yard (NPDES permit #NC0029246) for April and August 2015 and February
2016. No transcription errors were detected. The facility appears to be doing a good job of
accurately transcribing data.
Page 4
#5295 Leonard E. Stogner
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: June 15, 2016
Report reviewed by: Anna OstendorFf Date: June 20, 2016