HomeMy WebLinkAbout#5641_2016_0624_JS_FINALINSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5641
Laboratory Name:
Byers Environmental,
Inc.
Inspection Type:
Field Commercial Initial
Inspector Name(s):
Jason Smith
Inspection Date:
June 24 2016
Date Report Completed:
August 2 2016
Date Forwarded to Reviewer:
August 2, 2016
Reviewed by:
Nick Jones
Date Review Completed:
August 3, 2016
Cover Letter to use:
❑ Insp. Initial
❑ Insp. Reg.
❑ Insp. No Finding
❑ Insp. CP
® Corrected
❑ Insp. Reg. Delay
Unit Supervisor/Chemist III:
Todd Crawford
Date Received:
August 3, 2016
Date Forwarded to Admin:
August 5, 2016
Date Mailed:
August 8 2016
Special Mailing Instructions:
Water Resources
ENVIRONMENTAL QUALITY
August 8, 2016
5641
Mr. Donald Byers
Byers Environmental, Inc.
PO Box 729
Pisgah Forest, NC 28768
PAT MCCRORY
DONALD R. VAN DER VAART
,.P;
S. JAY ZIMMERMAN
SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Byers:
Enclosed is a report for the inspection performed on June 24, 2016 by Jason Smith. 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
electronic mail, or if you have questions or need additional information, please contact me at (919) 733-
3908 ext. 251.
Sincerely,
Todd Crawford
Technical Assistance & Compliance Specialist
NC WW/GW Laboratory Certification Branch
Attachment
cc: Jason Smith, Dana Satterwhite, Master File #5641
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:lideg.nc.gov/aboutidivisions/water-resourcestwater-resources•data/water-sciences-home-paste/laboratoN-certification-branch
LABORATORY NAME: Byers Environmental, Inc.
ADDRESS: 470 Asheville Highway
Suite H
Brevard, NC 28712
NPDES PERMIT #: NC0025381 and NC0021733
CERTIFICATE #: 5641
DATE OF INSPECTION: June 24, 2016
TYPE OF INSPECTION: Field Commercial Initial
AUDITOR(S): Jason Smith
LOCAL PERSON(S) CONTACTED: Don Byers
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:
The laboratory has all the equipment necessary to perform the analyses, maintaining separate
instrumentation at each facility.
All required Proficiency Testing (PT) samples for the 2016 PT calendar year have not yet been
analyzed. The laboratory is reminded that results must be received by this office directly from the
vendor by September 30, 2016. The laboratory is participating in a study that closes in August,
2016.
Contracted analyses are performed by Environmental Testing Solutions, Inc. (Certification #600).
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 performed properly. The NC WW/GW LC 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 beginning June 27, 2016, error
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corrections are performed properly using a single line to mark through the error and initialing and
dating the error) was received by email on July 23, 2016. No further response is necessary for
this Finding.
Comment: All data was not recorded using indelible ink. The waterproof notebooks sometimes
used in the field require the use of a pencil. The NC WW/GW LC Quality Assurance Policies for
Field Laboratories document states: All data and log entries must be written in indelible ink. Pencil
entries are not acceptable. Notification of acceptable corrective action (i.e., a statement that
beginning June 27, 2016, all documentation is recorded in indelible ink) was received by email on
July 23, 2016. No further response is necessary for this Finding.
Comment: The laboratory was not transcribing data qualifiers from the contract laboratory reports
to the electronic Discharge Monitoring Report (eDMR). The NC WW/GW LC Quality Assurance
Policies for Field Laboratories document states: When quality control (QC) failures occur, the
laboratory must attempt to determine the source of the problem and must apply corrective
action. Part of the corrective action is notification to the end user. If data qualifiers are used to
qualify samples not meeting QC requirements, the data may not be useable for the intended
purposes. It is the responsibility of the laboratory to provide the client or end -user of the data
with sufficient information to determine the usability of the qualified data. Where applicable, a
notation must be made on the Discharge Monitoring Report (DMR) form in the comment
section or on a separate sheet attached to the DMR form 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 beginning with the June, 2016 eDMR all data
qualifiers will be documented on the eDMR) was received by email on July 23, 2016. No further
response is necessary for this Finding.
Proficiency Testing
Comment: The laboratory was not documenting Proficiency Testing (PT) sample analyses in the
same manner as environmental samples. The NC WW/GW LC Proficiency Testing Requirements
document, February 20, 2012, Revision 1.2 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 PT testing data
will be recorded on the daily benchsheet beginning with the August, 2016 PT study) was received
by email on July 23, 2016. No further response is necessary for this Finding.
Comment: The preparation of the Total Residual Chlorine (TRC) PT samples was not
documented. The NC WW/GW LC Proficiency Testing Requirements document, February 20,
2012, Revision 1.2 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 PT sample preparation will be documented beginning with the August, 2016 PT
study) was received by email on July 23, 2016. No further response is necessary for this
Finding.
Dissolved Oxygen — Standard Methods, 4500 O G-2001
pH — Standard Methods, 4500 H+ B-2000
Total Residual Chlorine — Standard Methods, 4500 CI G-2000
Comment: Meter calibration times were documented, but not clearly labeled. The NC WW/GW LC
Approved Procedure for the Analysis of pH, Approved Procedure for the Analysis of Dissolved
Oxygen and Approved Procedure for the Analysis of Total Residual Chlorine state: The following
must be documented in indelible ink whenever sample analysis is performed: Meter calibration and
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#5641 Byers Environmental, Inc.
meter calibration time(s). Notification of acceptable corrective action (i.e., updated benchsheets
with clearly labeled calibration times were put into use on June 24, 2016) was received by email on
July 23, 2016. No further response is necessary for this Finding.
Dissolved Oxygen — Standard Methods, 4500 O G-2001
pH — Standard Methods, 4600 H+ B-2000
Temperature — Standard Methods, 2550 B-2000
Total Residual Chlorine — Standard Methods, 4500 CI G-2000
Comment: Identification of instruments was not documented on the benchsheet. The NC WW/GW
LC Approved Procedure for the Analysis of pH, Approved Procedure for the Analysis of Dissolved
Oxygen, Approved Procedure for the Analysis of Total Residual Chlorine and Approved Procedure
for the Analysis of Temperature documents state: The following must be documented in indelible
ink whenever sample analysis is performed: Instrument/Thermometer Identification. Notification of
acceptable corrective action (i.e., updated benchsheets with instrument and thermometer
identification documented which were put into use on June 24, 2016) was received by email on
July 23, 2016. No further response is necessary for this Finding.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) and contract lab reports to eDMRs submitted to the North Carolina Division of Water
Resources. Data were reviewed for Marshall WWTP (NPDES permit # NC0021733) for January
and April, 2016 and Lake Lure WWTP (NPDES permit # NC0025381) for February, 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: Jason Smith Date: August 2, 2016
Report reviewed by: Nick Jones Date: August 3, 2016