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HomeMy WebLinkAbout#5090 - 08 - 2010 - FINALTo be attached to all inspection reports in-house only. Laboratory Cert. #: 5090 Laboratory Name_ Environmental, Inc. Inspection Type: Field Commercial Maintenance Inspector Name(s): Jason Smith Inspection Date: August, 19, 2010 Date Report Completed: October 4 2010 Date Forwarded to Reviewer: October 4 2010 Reviewed by: Todd Crawford Date Review Completed: October 5 2010 Cover Letter to use: Insp. Initial X Insp. Reg. Insp. No Finding Insp. CP Unit Supervisor: Gary Francies Date Received: 10/6/2010 Date Forwarded to Alberta: 10/14/2010 c� 10. 15. ) 'D Date Mailed: Beverly Eaves Perdue Governor 5090 Mr. Mark Teague Environmental, Inc. P.O. Box 954 Cullowhee, NC 28723 +®o Iwj ....,+�Y NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Coleen H. Sullins Director October 14, 2010 SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Teague: Dee Freeman Secretary Enclosed is a report for the inspection performed on August 19, 2010 by Jason Smith. I apologize for the delay in getting this report to you. Where finding(s) are cited in this report, a response is required. Within 30 days of receipt, please supply this office with a written item for item description of how these finding(s) were corrected. 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 email or if you have questions or need additional information please contact me at 828-296-4677. Sincerely, Gary Francies Unit Supervisor Laboratory Section CC: Jason Smith Master files 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: 919-733-30081 FAX: 919-733-6241 Internet: www.dwglab.org An Equal Opportunity \ Affirmative Action Employer Customer Service: 1-877-623-6748 www.ncwaterquality,org One Nor hCarolrna Naturally LABORATORY NAME: ADDRESS: CERTIFICATE #: DATE OF INSPECTION: TYPE OF INSPECTION: AUDITOR(S): LOCAL PERSON(S) CONTACTED: • • ' 'V 0 Environmental, Inc. P.O. Box 954 Cullowhee, NC 28723 5090 August 19, 2010 Field Commercial Maintenance Jason Smith Mark Teague, Elizabeth Wike, and JoeDavid Hall INTRODUCTION: This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for the analysis of environmental samples. GENERAL COMMENTS: The laboratory has all the equipment necessary to perform the analyses and consists of three operators, each operating several facilities. Findings E and H are new policies that have been implemented by our program since the last inspection. FINDINGS REQUIREMENTS COMMENTS AND RECOMMENDATIONS: General Laboratory Recommendation: Calibration logs are kept in separate notebooks for each analyst. However, it is very difficult to match specific meters to individuals because all meters are calibrated by one analyst. It is recommended that the calibration logs clearly identify the applicable meter that is being calibrated and which meter is used by each analyst on a particular day. A. Finding: Error corrections are not performed properly. Requirement: 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-QutQ, 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. All data and log entries must be written in indelible ink. Pencil entries are not acceptable. Ref: Quality Assurance Policies for Field Laboratories. Temperature — Standard Methods, 18`h Edition, 2550 B B. Finding: Temperature is not always analyzed within EPA holding time. Requirement: Immediate analysis is required. Ref: Code of Federal Regulations, Title 40, Part 136; Federal Register Vol. 72, No. 47, March 12, 2007; Table il. - - - Page 2 #5090 Environmental, Inc. Comment: When collecting samples in a hazardous area (such as highway bridges, etc.), measurement may be delayed only as long as it takes to transport and analyze the samples at a safe location near the collection point. Comment: As discussed during the inspection, the analyst considers one sample collection site to be too hazardous to allow immediate analysis. This finding does not apply to this sample location; however this was not the only sample location where samples were not analyzed immediately. Temperature — Standard Methods, 18`h Edition, 2550 B Dissolved Oxygen — Standard Methods, 18th Edition, 4500 O G C. Finding: The laboratory was not able to locate the documentation of the temperature sensor check of two of the Dissolved Oxygen meters. The temperature sensor of the other Dissolved Oxygen meter had not been checked. 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 signature or initials of the analyst, and proper units of measure for all analyses. Ref: 15A NCAC 2H .0805 (g) (1). Requirement: All thermometers and temperature measuring devices must be checked every 12 months against a NIST certified or NIST traceable thermometer and the process documented. Ref: Technical Assistance for Field Analysis of Dissolved Oxygen and Technical Assistance for Field Analysis of Temperature. Please submit a copy of the temperature sensor checks for all Dissolved Oxygen meters with the reply to this report. D. Finding: The temperature corrections are not posted on the meters. Requirement: The temperature correction (even if it is zero) must be posted on the meter as well as in hard copy format (to be retained for 5 years). Ref: Technical Assistance for Field Analysis of Dissolved Oxygen and Technical Assistance for Field Analysis of Temperature. Total Residual Chlorine — Standard Methods, 18ch Edition, 4500 CI G E. Finding: Performance testing (PT) samples are not analyzed in the same manner as environmental samples. Requirement: 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. Ref: Quality Assurance Policies for Field Laboratories, Comment: Analyze PT samples on the same program, using the same procedure that is used for sample analysis. NPDES samples are analyzed using the Ultra Low Level TRC (pg/L) internal instrument standard curve; however, PT samples are analyzed using the Regular Level TRC (mg/L) internal instrument curve. Recommendation: Regular level PT samples may be diluted so that concentrations are within -" the verified (bracketed) curve range. Since the dilution process can introduce additional error, it is recommended that the facility analyze a low level TRC PT sample. These are currently available from many vendors. Page 3 #5090 Environmental, Inc. F. Finding: The gel standards do not have true values assigned. Requirement: Purchased "Gel -type" or sealed liquid ampoule standards may be used for daily calibration verification only. These standards must be verified initially and every 12 months thereafter, with the standard curve. The assigned values will be used for the next twelve months, or until a new curve verification is performed. The gel/liquid standard verification must be performed for each instrument on which they are to be used. If multiple, instruments and/or standard sets are used, each must have assigned values specific for the instrument and standard set. Ref: Technical Assistance for Field Analysis of Total Residual Chlorine. G. Finding: A new meter has recently been put into use without verifying the internal curve. Requirement: Instruments are to be calibrated or a calibration check must be performed prior to analysis of samples each day compliance monitoring is performed. Ref: Technical Assistance for Field Analysis of Total Residual Chlorine. Please submit: a copy of the calibration verification with the reply to this report. Comment: There are four calibration options described in the Technical Assistance for Field Analysis of Total Residual Chlorine. The laboratory has chosen Option 1 for the other meters. pH — Standard Methods, 18`" Edition, 4500 H+ B Dissolved Oxygen — Standard Methods, 181" Edition, 4500 0 G Total Residual Chlorine —Standard Methods, 18`" Edition, 4500 Cl G H. Finding: Post calibration checks are not performed at mid -day for pH and TRC. The Dissolved Oxygen meters are not recalibrated every four hours. Requirement: If compliance samples are analyzed throughout the day, a post calibration check must be analyzed mid -day and at the end of the run (i.e., roughly every 4 hours based on an eight hour day). Ref: Technical Assistance for Field Analysis of pH and Technical Assistance for Field Analysis of Total Residual Chlorine. Requirement: When performing analysis at multiple sampling locations, re -calibrations) must be performed every four hours. Ref: Technical Assistance for Field Analysis of Dissolved Oxygen. pH — Standard Methods, 181" Edition, 4500 H+ B Temperature — Standard Methods, 18t" Edition, 2550 B Dissolved Oxygen — Standard Methods, 1$t" Edition, 4500 0 G j Total Residual Chlorine — Standard Methods, 18°h Edition, 4500 Cl G 1. Finding: The time of collection and analysis is not clearly documented. 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 signature or initials of the analyst, and proper units of measure for all analyses. Ref: 15A NCAC 2H .0805 (g) (1). Comment: For analyses performed in- situ (in stream or on site), a general statement reflecting this may be added to the benchsheet and/or the column header may be modified to "collection/analysis time". Page 4 #5090 Environmental, Inc. IV. PAPER TRAIT_ INVESTIGATION: The paper trail consisted of comparing field testing records and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data were reviewed for Mark Laurel Homeowners Association (NPDES permit 4NC0061930), Hiwassee Dam School (NPDES permit #NC0035386), and Dogwood (NPDES permit #NC0085952) for May and June, 2010, No transcription errors were detected. 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 lab to produce quality data and meet certification requirements. The inspector would like to thank the staff for its assistance during the inspection and data review process. Please respond to all findings. Report prepared by: Jason Smith Date: October 4, 2010 Report reviewed by: Todd Crawford Date: October 5, 2010