Loading...
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