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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 Page 2 #5641 Byers Environmental, Inc. 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 Page 3 #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