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HomeMy WebLinkAbout#5639_2018_0315_BS_MC_FINALTo be attached to all inspection reports in-house only. Laboratory Cert. #: 5639 Laboratory Name: Shealy Environmental Services, Inc. Inspection Type: Field Commercial Maintenance Inspector Name(s): Beth Swanson, Michael Cumbus Inspection Date: March 15, 2018 Date Forwarded for Initial Review: March 27, 2018 Initial Review by: Anna Ostendorff Date Initial Review Completed: . March 28, 2018 Cover Letter to use: ❑ Insp. Initial ® Insp. Reg ❑Insp. No Finding ❑Insp. CP ❑Corrected ❑Insp. Reg. Delay Unit Supervisor/Chemist III: Beth Swanson Date Received: March 29, 2018 Date Forwarded to Admin.: April 2, 2018 Date Mailed: April 3, 2018 Special Mailing Instructions: April 3, 2018 5639 Ms. Wendy Plessinger Shealy Environmental Services Inc. 106 Vantage Point Dr West Columbia, SC 29172 ROY COOPER MICHAEL S. REGAN Se LINDA CULPEPPER Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Ms. Plessinger: Enclosed is a report for the inspection performed on March 15, 2018 by Michael Cumbus. Where Finding(s) are cited in this report, a response is required. Within thirty days of receipt, please supply this office with a written item for item description of how these Finding(s) were corrected. Please describe the steps taken to prevent recurrence and include an implementation date for each corrective action. If the Finding(s) cited in the enclosed report are not corrected, enforcement actions may be recommended. For Certification maintenance, your laboratory must continue to carry out the requirements set forth in 15A NCAC 2H .0800. A copy of the laboratory's Certified Parameter List at the time of the audit is attached. This list will reflect any changes made during the audit. 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 (919) 733-3908 ext. 259. Sincerely, ?J Beth Swanson Technical Assistance & Compliance Specialist Division of Water Resources Attachment cc: Dana Satterwhite, Michael Cumbus, Masterfile #5639 _=•:1 •' CERTIFICATE : W Me Shealy Environmental Services, Inc 228 Westinghouse Blvd., Suite 101 Charlotte, NC 28273 5369 March 15, 2018 Field Commercial Maintenance Beth Swanson and Michael Cumbus LOCAL PERSON(S) CONTACTED: Stephanie Atkins and Cal Easter INTRODUCTION: This laboratory was inspected by representatives 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: Records are well organized and easy to retrieve. Staff were forthcoming and seemed eager to adopt necessary changes. The Findings cited are mainly documentation -related in order to bolster the laboratory data's legal defensibility. All required Proficiency Testing (PT) Samples have been analyzed for the 2018 PT Calendar Year and the graded results were 100% acceptable. 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 Shealy Environmental Services, Inc. (Cert #329). Quality Assurance Policies for Field Laboratories and Approved Procedure documents for the analysis of the facility's currently certified Field Parameters were provided at the time of the inspection. Page 2 #5639 Shealy Environmental Services, Inc. Documentation A. Finding: The laboratory needs to increase the traceability of documentation of purchased materials and reagents. Requirement: 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 (where specified). This information as well as the vendor and/or manufacturer, lot number, and expiration date must be retained for primary standards, chemicals, reagents, and materials used for a period of five years. Consumable materials such as pH buffers, lots of pre -made standards and/or media, solids and bacteria filters, etc. are included in this requirement. Ref: NC WW/GW LC Policy. Comment: The laboratory is transferring pH buffers from the parent bottles in Shealy Environmental's main laboratory into smaller containers for use at the field location. All required traceability information is written on the container except for the Date Opened. B. Finding: The laboratory benchsheet was lacking pertinent data: Time of sample analysis. Requirement: 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. Ref: 15A NCAC 2H .0805 (g) (1). Requirement: The following must be documented in indelible ink whenever sample analysis is performed: Date and time of sample analysis. Ref: 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. Comment: The benchsheet only documents the sample collection date and time for Dissolved Oxygen (DO), Temperature and pH. Most analyses are taken in situ, but there is no notation of this or a separate time for sample analysis. C. Finding: Documentation of the calibration variables for the DO meter does not include all pertinent data. Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A NCAC 2H .0805 (g) (1). Requirement: The following must be documented in indelible ink whenever sample analysis is performed: calibration variables (elevation, temperature, barometric pressure [in mmHg], salinity). Ref: NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen. Comment: The laboratory documents temperature during meter calibration. D. Finding: The laboratory benchsheet was lacking pertinent data: Units of measure. Requirement: 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 Page 3 #5639 Shealy Environmental Services, Inc. signature or initials of the analyst, and proper units of measure for all analyses. Ref: 15A NCAC 2H .0805 (g) (1). Requirement: The following must be documented in indelible ink whenever sample analysis is performed: Units of measure. Ref: NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen, NC WW/GW LC Approved Procedure for the Analysis of pH and INC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine. Comment: The laboratory recorded results for DO, pH and Total Residual Chlorine (TRC) on the Chain of Custody (COC) as well as a field benchsheet. The COC form did not contain units of measure for any parameter other than Temperature. E. Finding: The laboratory benchsheet was lacking pertinent data for Temperature: Instrument identification and method reference. Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A NCAC 21-1.0805 (g) (1). Requirement: The following must be documented in indelible ink whenever sample analysis is performed: Instrument identification (serial number preferred) and method reference. Ref: NC WW/GW LC Approved Procedure for the Analysis of Temperature. Proficiency Testing F. Finding: The laboratory is not documenting the preparation of PT Samples. Requirement: PT Samples received as ampules are diluted according to the Accredited PT Sample Provider's instructions. It is important to remember to document the preparation of PT Samples in a traceable log or other traceable format. The diluted PT Sample then becomes a routine Compliance Sample and is added to a routine sample batch for analysis. No documentation is needed for whole volume PT Samples which require no preparation (e.g., pH) but it is recommended that the instructions be maintained. Ref: Proficiency Testing Requirements, May 31, 2018, Revision 2.0 Comment: Dating and initialing the instruction sheet for the preparation of the Total Residual Chlorine PT Sample would satisfy the documentation requirement. G. Finding: PT Samples have not been distributed among all analysts from year to year. Requirement: Laboratories shall also ensure that, from year to year, PT samples are equally distributed among personnel trained and qualified for the relevant tests and instrument (when more than one instrument is used for routine Compliance Sample analyses), that represents the routine operation of the work group at the time the PT Sample analysis is conducted. Ref: Proficiency Testing Requirements, May 31, 2017, Revision 2.0. Chlorine, Total Residual — Standard Methods, 4500 CI G-2011 (Aqueous) Comment: The laboratory verifies the factory set curve to a concentration of 15 pg/L, which is low enough to meet all current clients' permit limits. The laboratory currently has clients who request reporting limits that are higher than this value (i.e., 28 lag/L and 50 lag/L) so results are reported to these clients as "<" the respective concentration. Reporting <50 lag/L does not allow clients to demonstrate compliance if they have a permit limit. Page 4 #5639 Shealy Environmental Services, Inc. Recommendation: It is recommended that the meter zero blank and gel -type blanks be removed from the daily benchsheet to avoid confusion. Recommendation: It is recommended that subsequent calibration curve verifications be performed using the same type of reagents as used for compliance sample testing. The most recent calibration curve verification was performed using DPD powder reagents, while liquid reagents are currently used for compliance sampling. H. Finding: The laboratory did not verify the gel -type standard concentration before initial use. Requirement: Purchased "gel -type" or sealed liquid ampoule standards may be used for daily standard curve verification only. These standards must be verified initially and every 12 months thereafter, with the standard curve. When this is done, these standards may be used after the manufacturer's expiration date. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine. Chlorine, Total Residual — Standard Methods, 4500 CI G-2011 (Aqueous) pH — Standard Methods, 4500 H+ B-2011 (Aqueous) I. Finding: The laboratory does not report results of all tests on the characteristics of the effluent when duplicate sample analyses are performed. Requirement: The results of all tests on the characteristics of the effluent, including but not limited to NPDES monitoring requirements, shall be reported on the monthly report forms. Ref 15A NCAC 2B .0506 (b) (3) (J). Comment: The laboratory reports the first value as the sample result on client reports. For pH, both values would need to be reported since pH cannot be averaged. For TRC, the sample and duplicate values could be averaged and reported. Comment: Duplicate analyses are not a required quality control element for Field parameters. Conductivity — EPA 120.1, Rev. 1982 (Aqueous) Comment: No compliance data for the State of North Carolina has been analyzed in the past few years. Comment: The temperatures used during the last Automatic Temperature Compensator (ATC) check were 23.6, 24.8 and 28.0 'C. When performing the next annual ATC check, the lowest temperature must bracket the expected range of sample temperatures. pH — Standard Methods, 4500 H+ B-2011 (Aqueous) J. Finding: Values were reported that exceed the method specified accuracy of 0.1 units. Requirement: 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. Ref: Standard Methods, 4500 H+ B-2011. (6). Page 5 #5639 Shealy Environmental Services, Inc. Temperature — Standard Methods, 2550 B-2010 (Aqueous) Comment: The lowest temperature checked during the last temperature sensor verification was 22.2 °C. The two temperatures used to check the temperature -sensing probe on the pH meter must bracket the expected compliance sample range. This is a new requirement since the last temperature sensor check was performed. 1 ocz, rT�itC�7 A The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks, etc.) and client reports. Data were reviewed for the following project numbers SG21021, TB14063, SG28031, S105015, S127007, SK27013, SL18028, TA29032, TB14030, TB16060, SL04039, SL27035, SL27015, TA10065. No transcription errors were observed. The facility appears to be doing a good job of accurately transcribing data. V. CONCLUSIONS: Correcting the above -cited Findings and implementing the Recommendations will help this laboratory to produce quality data and meet Certification requirements. The inspectors would like to thank the staff for their assistance during the inspection and data review process. Please respond to all Findings and include supporting documentation, implementation dates and steps taken to prevent recurrence for each corrective action. 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