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HomeMy WebLinkAbout#5586_10_2012_FINALkv; � $ it NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Charles Wakild, P. E. Governor Director November 8, 2012 5586 Mr. Norman Long Reed Gold Mine 9261 Reed Mine Road Midland NC, 28107 Dee Freeman Secretary SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Long: Enclosed is a report for the inspection performed on October 4 2012 by Chet Whiting. 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 828-296-4677. Sincerely, Gary Francies Certification Unit Supervisor Laboratory Section CC: Chet Whiting Master File DENR DWQ Laboratory Section NC Wastewater/Groundwater Laboratory Certification Branch 1623 Mail Service Center, Raleigh, North Carolina 27699-1623 Location: 4405 Reedy Creek Road. Raleigh, North Carolina 27607-6445 Phone: 919-733-3908 \ FAX: 919-733-6241 Internet: www.dwglab.org One North Carolina atu t An Equal Opportunity \ Affirmative Action Employer On -Site Inspection Report LABORATORY NAME: NDMR PERMIT # ADDRESS: CERTIFICATE #: DATE OF INSPECTION: TYPE OF INSPECTION: AUDITOR(S): LOCAL PERSON(S) CONTACTED: I. INTRODUCTION: Reed Gold Mine WQ0006946 9261 Reed Mine Road Midland NC, 28107 5586 October 4, 2012 Field Maintenance Chet Whiting Norman Long 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 is neat and well organized and has all the equipment necessary to perform the analyses. Copies of the following documents were given to laboratory personnel during the inspection: Quality Assurance Policies for Field Laboratories, Approved Procedure for Field Analysis of pH, Approved Procedure for Field Analysis of Dissolved Oxygen, Approved Procedure for Field Analysis of Temperature, and Approved Procedure for Field Analysis of Total Residual Chlorine. Contracted analyses are performed by K & W Laboratories (Certification #559) and PAR Laboratories Inc. (Certification #20). III. FINDINGS REQUIREMENTS COMMENTS AND RECOMMENDATIONS: Comment: No instances were observed, however the laboratory was not aware that any data that does not meet all quality control requirements is required to be qualified on the Discharge Monitoring Report (DMR), including contract laboratory data. The 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 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. Comment: The laboratory needed to implement documentation of materials and reagents. 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, Page 2 #5586 Reed Gold Mine Date Opened (in use), Vendor, Lot Number, and Expiration Date. A system (e.g., traceable identifiers) must be in place that links standard/reagent preparation information to analytical batches in which the solutions are used. Documentation of solution preparation must include the analyst's initials, date of preparation, the volume or weight of standard(s) used, the solvent and final volume of the solution. This information as well as the vendor, 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. This requirement is a new policy that has been implemented by our program since the last inspection. Notification of acceptable corrective action (i.e., a statement that a new field sheet that includes traceability information has been adopted) was received by email on November 4, 2012. No further response is necessary for this finding. Comment: The laboratory was not documenting the preparation of Proficiency Testing samples. The Proficiency Testing Requirements, February 20, 2012, Revision 1.2 document 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. This requirement is a new policy that has been implemented by our program since the last inspection. Notification of acceptable corrective action (i.e., a statement that PT sample preparation will be documented in 2013) was received by email on October 12, 2012. No further response is necessary for this finding. Comment: The laboratory was not documenting Proficiency Testing (PT) samples in the same manner as environmental samples (i.e., in 2013). The Proficiency Testing Requirements, February 20, 2012, Revision 1.2. document states: The analysis of PT samples is designed to evaluate the entire process used to routinely report environmental analytical results. Therefore, PT samples must be analyzed and the process documented in the same manner as environmental samples. This requirement is a new policy that has been implemented by our program since the last inspection. Notification of acceptable corrective action (i.e., a statement that PT samples will be documented in the same manner as environmental samples) was received by email on October 12, 2012. No further response is necessary for this finding. pH — Standard Methods, 18t" Edition, 4500 H+ B Comment: Values were reported that exceed the method specified accuracy (0.1 S.U.) for this analysis. 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 pH results are now being reported to 0.1 S.U.) was received by e-mail on October 12, 2012. No further response is necessary for this finding. Comment: The manufacturer expiration date for the pH 10 buffer was exceeded. The Quality Assurance Policies for Field Laboratories document states: Adherence to manufacturer expiration dates is required. Chemicals, reagents, standards, consumables exceeding the expiration date can no longer be considered reliable. If the expiration is only listed as a month and year (with no specific day of the month), the last day of the month will be considered the actual date of expiration. Monitor materials for changes in appearance or consistency. Any changes may indicate potential contamination and the item should be discarded, even if the expiration date is not exceeded. If no expiration date is given, the laboratory must have a policy for assigning an expiration date. If no date received or expiration date can be determined, the item should be discarded. Notification of acceptable corrective Page 3 #5586 Reed Gold Mine action (i.e., the out of date buffer was replaced) was received by e-mail on October 12, 2012. No further response is necessary for this finding. Comment: A calibration check standard was not analyzed. North Carolina Wastewater/Groundwater Laboratory Certification Approved Procedure for Field Analysis of pH document states: For routine work, use a pH meter accurate and reproducible to 0.1 pH unit with a range of 0 to 14, equipped with a temperature compensation device. Follow all manufacturers' recommendations for the calibration of the meter each analysis day. The meter must be calibrated with at least two buffers. In addition to the calibration standards the meter must be verified with a third calibration standard. The calibration and check standard buffer must bracket the range of the samples being analyzed. The check standard buffer must read within a range of ± 0.1 pH units to be acceptable. Notification of acceptable corrective action (i.e., a check buffer is analyzed each day of sample analysis was received by e-mail on October 12, 2012. No further response is necessary for this finding. IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing field testing records and contract lab reports to Non Discharge Monitoring Reports (NDMRs) submitted to the North Carolina Division of Water Quality. Data were reviewed for Reed Gold Mine (NDMR Permit WQ0006946) for April, May and June, 2012. 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: Chet Whiting Date: October 12, 2012 Report reviewed by: Todd Crawford Date: November 5, 2012