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HomeMy WebLinkAbout#5650_2022_1215_TLH_FINAL NC Department of Environmental Quality | Division of Water Resources | Laboratory Certification Branch 4405 Reedy Creek Road | 1623 Mail Service Center | Raleigh, North Carolina 27699-1623 919-733-3908 December 28, 2022 5650 Ms. Katie Hackney Groundwater Management Associates Inc. (GMA) 4300 Sapphire Court, Suite 100 Greenville, NC 27834 Subject: North Carolina Wastewater/Groundwater Laboratory Certification Branch (NC WW/GW LCB) Maintenance Inspection Dear Ms. Hackney: Enclosed is a report for the inspection performed on December 15, 2022 by Tom Halvosa. Where Finding(s) are cited in this report, a response is required. Within thirty days, 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 02H .0800. A copy of the laboratory’s Certified Parameter List at the time of the audit is attached. This list will not 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 have questions or need additional information, please contact me at (919) 733- 3908 Ext. 259. Sincerely, Beth Swanson Technical Assistance & Compliance Specialist Division of Water Resources Attachment cc: Tom Halvosa, Todd Crawford, #5650 file On-Site Inspection Report LABORATORY NAME: Groundwater Management Associates Inc. (GMA) ADDRESS: 4300 Sapphire Court, Suite 100 Greenville, NC 27834 CERTIFICATE #: 5650 DATE OF INSPECTION: December 15, 2022 TYPE OF INSPECTION: Field Commercial Initial AUDITOR: Tom Halvosa LOCAL PERSON CONTACTED: Katie Hackney I. INTRODUCTION: This laboratory was inspected by a representative of the North Carolina Wastewater/Groundwater Laboratory Certification Branch (NC WW/GW LCB) to verify its compliance with the requirements of 15A NCAC 02H .0800 for the analysis of compliance monitoring samples. II. GENERAL COMMENTS: The facility is neat and well organized and has all the equipment necessary to perform the analyses. Staff was forthcoming and responded well to suggestions from the auditor. All required Proficiency Testing (PT) Samples have been analyzed for the 2022 PT Calendar Year and the graded results were 100% acceptable. Any time changes are made to laboratory procedures, QA/SOP document(s) must be updated and relevant staff retrained. Staff must acknowledge that they have read and understand the changes as part of the documented training program. The same requirements apply when changes are made in response to Findings, Recommendations or Comments listed in this report, to ensure the methods are being performed as stated, references to methods are accurate, and the QA and/or SOP document(s) is in agreement with each approved practice, test, analysis, measurement, monitoring procedure or regulatory requirement being used in the laboratory. In some instances, the laboratory may need to create an SOP to document how new functions or policies will be implemented. Revisions to the SOPs, based on the Findings, Comments and Recommendations within this report must be submitted to this office by July 1, 2023. The laboratory is reminded that SOPs are required to be reviewed at least every two years and are intended to describe procedures exactly as they are to be performed. Use of the word “should” is not appropriate when describing requirements (e.g., Quality Control (QC) frequency, acceptance criteria, etc.). Evaluate all SOPs for the proper use of the word “should”. Contracted analyses are performed by Pace Analytical Services LLC - Huntersville NC (Certification # 12), Environmental Chemists, Inc. (EnviroChem) (Certification # 94) and Waypoint Analytical – Charlotte (Certification # 402). Page 2 # 5650 Groundwater Management Associates Inc. (GMA) Approved Procedure documents for the analysis of the facility’s currently certified Field Parameters were provided at the time of the inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation A. Finding: Error corrections are not properly performed. Requirement: All documentation errors shall 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; instead the correction shall be written adjacent to the error. The correction shall be initialed by the responsible individual and the date of change documented. Ref: 15A NCAC 02H .0805 (g) (1). Comment: There were multiple instances of improper error corrections as well as the use of correction fluid. Conductivity – Standard Methods, 2510 B-2011 (Aqueous) B. Finding: The laboratory is not analyzing a second-source calibration verification check standard. Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (4). Requirement: Analyze and document a second-source calibration verification check standard prior to compliance sample analysis. It is recommended that this standard value approximate (may be higher or lower than the calibration standard, as applicable) the expected range of sample values measured. The value obtained for the calibration verification check-standard must read within 10% of the true value of the calibration verification check standard. If the obtained value is outside of the ±10% range, corrective action must be taken. Ref: NC WW/GW LCB Approved Procedure for the Analysis of Specific Conductance (Conductivity). C. Finding: The Automatic Temperature Compensator (ATC) check is not being performed. Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (4). Requirement: The ATC must be verified prior to initial use and annually (i.e., 12 months) thereafter at two temperatures by analyzing a standard or sample at 25°C (i.e., the temperature to which conductivity values are reported) and a temperature(s) that brackets the temperature ranges of the environmental samples routinely analyzed. This may require the analysis of a third temperature reading that is > 25°C (see #3 below). The manner in which the ATC is verified may depend upon the meter’s capabilities and the manufacturer’s instructions. The following is one option. 1. Pour an adequate amount of conductivity standard or sample into a beaker or other container and analyze at 25°C. Document the temperature and conductivity value. 2. Lower the temperature of the standard or sample (e.g., by placing the container in a refrigerator or ice chest) to less than the lowest anticipated sample temperature and analyze. Document the temperature and conductivity value. Page 3 # 5650 Groundwater Management Associates Inc. (GMA) 3. If samples greater than 25°C are to be analyzed, perform the following additional step: Raise the temperature above 25°C to greater than the highest anticipated sample temperature (e.g., by placing the container in a hot water bath) and analyze. Document the temperature and conductivity value. As the temperature increases or decreases, the value of the conductivity standard or sample must be within ±10% of the true value of the standard or ±10% of the value of the sample at 25°C. If not, corrective action must be taken. Ref: NC WW/GW LCB Approved Procedure for the Analysis of Specific Conductance (Conductivity). D. Finding: The laboratory is not performing a post-analysis calibration verification when performing multiple sample analyses. Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (4). Requirement: When performing multiple sample analyses, a post-analysis calibration verification must be analyzed at the end of the run. It is recommended that a mid-day or a mid-batch calibration verification be performed when samples are analyzed over an extended period of time. The value obtained for the post-analysis calibration verification check-standard must read within 10% of the standard’s true value. If the obtained value is outside of the ±10% range, corrective action must be taken. If recalibration is necessary, all samples analyzed since the last acceptable calibration verification must be reanalyzed, if possible. If samples cannot be reanalyzed, the data must be qualified. Ref: NC WW/GW LCB Approved Procedure for the Analysis of Specific Conductance (Conductivity). Dissolved Oxygen – Standard Methods, 4500 O G-2016 (Aqueous) E. Finding: When analyses are performed at multiple sample sites, the laboratory is not calibrating prior to sample analysis at each sample site or performing a post-analysis calibration verification. Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (4). Requirement: When performing analyses at multiple sample sites, the meter must be calibrated at each sample site prior to analysis or a post-analysis calibration verification must be performed at the end of the run, regardless of meter type. The calculated theoretical DO value must verify the meter reading within ±0.5 mg/L. If the meter verification does not read within ±0.5 mg/L of the theoretical DO, corrective action must be taken. If the meter is not calibrated at each sample site, it is recommended that a mid-day calibration be performed when samples are extended over an extended period of time. Ref: NC WW/GW LCB Approved Procedure for the Analysis of Dissolved Oxygen (DO). pH – Standard Methods, 4500 H+ B-2011 (Aqueous) F. Finding: The laboratory is not analyzing a check standard buffer after calibration and prior to sample analysis. Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (4). Requirement: Instruments are to be calibrated according to the manufacturer’s calibration procedure prior to analysis of samples each day compliance monitoring is performed. Page 4 # 5650 Groundwater Management Associates Inc. (GMA) Calibration must include at least two buffers. The meter calibration must be verified with a third standard buffer solution (i.e., check buffer) prior to sample analysis. Ref: NC WW/GW LCB Approved Procedure for the Analysis of pH. G. Finding: The laboratory is not analyzing a post-analysis check standard buffer when analyses are performed at multiple sample sites in a single day. Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (4). Requirement: When performing analyses at multiple sample sites, a post-analysis calibration verification using the check standard buffer must be analyzed at the end of the run. It is recommended that a mid-day check standard buffer be analyzed when samples are analyzed over an extended period of time. The post-analysis check standard buffer(s) must read within ±0.1 S.U. or corrective actions must be taken. If recalibration is necessary, all samples analyzed since the last acceptable calibration verification must be reanalyzed, if possible. If samples cannot be reanalyzed, the data must be qualified. Ref: NC WW/GW LCB Approved Procedure for the Analysis of pH. Temperature – Standard Methods, 2550 B-2010 (Aqueous) H. Finding: The compliance temperature-measuring device is not checked at two temperatures that bracket the range of observed sample temperatures. Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (4). Requirement: To check a compliance temperature-measuring device, compare readings at two temperatures that bracket the range of compliance samples routinely analyzed against a Reference Temperature-Measuring Device and record all four readings. The readings from both devices must agree within 0.5ºC. If they do not, the device may not be used for temperature compliance monitoring. Ref: NC WW/GW LCB Approved Procedure for the Analysis of Temperature. Comment: The laboratory only performs a comparison check at one temperature. IV. PAPER TRAIL INVESTIGATION: No paper trail was performed. The laboratory does not currently have any clients that require compliance sampling. The laboratory is maintaining certification for future needs. V. CONCLUSIONS: Correcting the above-cited Findings will help this laboratory to produce quality data and meet Certification requirements. The inspector 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. Report prepared by: Tom Halvosa Date: December 19, 2022 Report reviewed by: Jill Puff Date: December 20, 2022 Certificate Number:5650 Effective Date:1/1/2022 Expiration Date:12/31/2022 Lab Name:Groundwater Management Associates Inc. (GMA) Address:4300 Sapphire Court, Suite 100 Greenville, NC 27834 North Carolina Wastewater/Groundwater Laboratory Certification Certified Parameters Listing Date of Last Amendment:11/1/2021 The above named laboratory, having duly met the requirements of 15A NCAC 2H.0800, is hereby certified for the measurement of the parameters listed below. CERTIFIED PARAMETERS INORGANIC CONDUCTIVITY SM 2510 B-2011 (Aqueous) DISSOLVED OXYGEN SM 4500 O G-2016 (Aqueous) pH SM 4500 H+B-2011 (Aqueous) TEMPERATURE SM 2550 B-2010 (Aqueous) This certification requires maintance of an acceptable quality assurance program, use of approved methodology, and satisfactory performance on evaluation samples. Laboratories are subject to civil penalties and/or decertification for infractions as set forth in 15A NCAC 2H.0807.