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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
August 17, 2022
5752
Mr. Reggie Reeves
GEL Engineering of NC Inc.
1270 Hendersonville Road, Suite #6
Asheville, NC 28803
Subject: North Carolina Wastewater/Groundwater Laboratory Certification Branch (NC
WW/GW LCB) Maintenance Inspection
Dear Mr. Reeves:
Enclosed is a report for the inspection performed on July 27, 2022 by Jason Smith. 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. 251.
Sincerely,
Anna Ostendorff
Technical Assistance & Compliance Specialist
Division of Water Resources
Attachment
cc: Todd Crawford, Jason Smith, Master File #5752
On-Site Inspection Report
L ABORATORY NAME: GEL Engineering of NC Inc.
NPDES PERMIT #: NCG030070 and NCG030265
ADDRESS: 1270 Hendersonville Road, Suite #6
Asheville, NC 28803
CERTIFICATE #: 5752
DATE OF INSPECTION: July 27, 2022
TYPE OF INSPECTION: Field Commercial Initial
AUDITOR(S): Jason Smith
LOCAL PERSON(S) CONTACTED: Reggie Reeves
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. The
analyst was forthcoming and responded well to suggestions from the auditor. The laboratory currently only
analyzes stormwater samples which do not require NC WW/GW LCB certification.
All required Proficiency Testing (PT) Samples for the 2022 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, 2022.
The laboratory is reminded that 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 SOP, based on the
Findings, Comments and Recommendations within this report must be submitted to this office
by November 30, 2022.
The laboratory is also reminded that SOPs 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”.
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#5752 – GEL Engineering of NC Inc.
Contracted analyses are performed by Pace Analytical Services LLC - Asheville NC (Certification #40).
The Approved Procedure document for the analysis of the facility’s currently certified Field Parameter was
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: Error corrections are not dated.
B. Finding: The laboratory benchsheet is lacking required documentation: the sample collector.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data shall
be traceable to the associated sample analyses and shall consist of: the sample collector.
Each item shall be recorded each time samples are analyzed. Analyses shall conform to
methodologies found in Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (2)
(D).
C. Finding: The acceptance criterion evaluation of the check standard buffer is not documented
on the benchsheet.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data shall
be traceable to the associated sample analyses and shall consist of: the quality control
assessments. Ref: 15A NCAC 02H .0805 (g) (2) (O).
Comment: All of the check buffer values were acceptable in the data reviewed.
D. Finding: The laboratory is not documenting PT Sample analyses in the same manner as
routine Compliance Samples.
Requirement: All PT Sample analyses must be recorded in the daily analysis records as for
any Compliance Sample. This serves as the permanent laboratory record. Ref: Proficiency
Testing Requirements, February 19, 2020, Revision 5, Section 3.6.
Requirement: The laboratory shall retain all records necessary to facilitate historical
reconstruction of the analysis and reporting of analytical results for PT Samples. This means
the laboratory must have available and retain for five years [pursuant to 15A NCAC 02H .0805
(a) (7) (E) and (g) (1)] all of the raw data, including benchsheets, instrument printouts and
calibration data, for all PT Sample analyses and the associated QC analyses conducted by
all parameter methods. Ref: Proficiency Testing Requirements, February 19, 2020, Revision
5, Section 4.0.
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#5752 – GEL Engineering of NC Inc.
Requirement: The analysis of Proficiency Testing (PT) Samples is designed to evaluate the
entire process used to routinely analyze and report Compliance Sample results. PT Samples
must be analyzed the same as Compliance Samples. Also, documentation must be made on
the same benchsheets used for Compliance Samples. Ref: NC WW/GW LCB Proficiency
Testing Samples Analyzed and Documented Same as Compliance Samples Policy.
E. Finding: The laboratory does not have a documented plan for PT procedures.
Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. A
copy of each analytical method or Approved Procedure and Standard Operating Procedure
shall be available to each analyst and available for review upon request by the State
Laboratory. Standard Operating Procedure documentation shall state the effective date of the
document and shall be reviewed every two years and updated if changes in procedures are
made. Each laboratory shall have a formal process to track and document review dates and
any revisions made in all Standard Operating Procedure documents. Supporting Records
shall be maintained as evidence that these practices are implemented. Ref: 15A NCAC 02H
.0805 (g) (4).
Requirement: Laboratories must have a documented plan [this is usually detailed in the
laboratory’s Quality Assurance Manual or may be a separate Standard Operating Procedure
(SOP)] of how they intend to cover the applicable program requirements for Proficiency
Testing per their scope of accreditation. This plan shall cover any commercially available PT
Samples and any inter-laboratory organized studies, as applicable. The laboratory must also
be able to explain when PT Sample analysis is not possible for certain methods and provide
a description of what the laboratory is doing in lieu of Proficiency Testing. This shall be detailed
in the plan. The plan must also address the laboratory’s process for submission of PT Sample
results and related Corrective Action Reports (CARs). Ref: Proficiency Testing Requirements,
February 19, 2020, Revision 5, Section 3.0.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks, etc.) and
contract laboratory reports to Discharge Monitoring Reports submitted to the North Carolina Division of
Energy, Mineral and Land Resources. Data were reviewed for Dodge Mechanical Power Transmission
Company (NPDES permit # NCG030070) and Dave Steel Company (NPDES permit # NCG030265) for
March 2021, February 2022 and May 2022. 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 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: Jason Smith Date: August 10, 2022
Report reviewed by: Jill Puff Date: August 10, 2022
Certificate Number:5752
Effective Date:1/1/2022
Expiration Date:12/31/2022
Lab Name:GEL Engineering of NC Inc.
Address:1270 Hendersonville Road, Suite #6
Asheville, NC 28803
North Carolina Wastewater/Groundwater Laboratory Certification
Certified Parameters Listing
Date of Last Amendment:
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
pH
SM 4500 H+B-2011 (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.