HomeMy WebLinkAbout#5445_2020_1106_JMS_FINAL
December 3,2020
5445
Ms. Melanie Kemp
Anchor QEA of North Carolina PLLC
231 Haywood Street
Asheville, NC 28801
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW
LC) Maintenance Inspection
Dear Ms. Kemp:
Enclosed is a report for the inspection performed on November 6, 2020 by Jason Smith. Where
Finding(s) are cited in this report, a response is required. Within thirty days of receipt, please
supply this office with a written item for item description of how th ese 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 2H .0800.
A copy of the laboratory’s Certified Parameter List at the time of the audit is attached. This list
will 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 wish to obtain an electronic copy of this report by email or if you have
questions or need additional information, please contact me at (919) 733-3908 Ext. 251.
Sincerely,
Todd Crawford
Environmental Program Supervisor II
NC WW/GW Laboratory Certification
Branch
Attachment
cc: Jason Smith, Master File #5445
Inspection Report
LABORATORY NAME: Anchor QEA of North Carolina PLLC
WATER QUALITY PERMIT #: WQ0004797
NC GENERAL PERMIT #: NCG030026 and NCG030499
ADDRESS: 231 Haywood Street
Asheville, NC 28801
CERTIFICATE #: 5445
DATE OF INSPECTION: November 6, 2020
TYPE OF INSPECTION: Field Commercial Maintenance
AUDITOR(S): Jason Smith
LOCAL PERSON(S) CONTACTED: Matthew Fields and Jennifer Verde
I. 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 02H .0800 for the analysis of compliance monitoring samples.
II. GENERAL COMMENTS:
The inspection was performed remotely due to the coronavirus pandemic. The laboratory submitted the
requested documentation and pictures of their reagents and instruments electronically. The inspection
was performed by WebEx teleconference on November 6, 2020.
The laboratory has all the equipment necessary to perform the analyses. Benchsheets are well
designed, easy to follow and concise. Staff members were forthcoming and responded well to
suggestions from the auditor.
All required Proficiency Testing (PT) Samples have been analyzed for the 2020 PT Calendar Year and the
graded results were 100% acceptable.
Contracted analyses are performed by Pace Analytical Services, LLC – Asheville, NC (Certification # 40).
The laboratory submitted their Quality Assurance (QA) and/or Standard Operating Procedure (SOP)
document(s) in advance of the inspection. These documents were reviewed and editorial and
substantive revision requirements and recommendations were made by this program outside of this
formal report process. Although subsequent revisions were not requested to be submitted, they must be
completed by May 2021.
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The laboratory is reminded that any time changes are made to laboratory procedures, the laboratory
must update the QA/SOP document(s) and inform relevant staff. Any changes made in response to the
pre-audit review or to Findings, Recommendations or Comments listed in this report must be
incorporated to insure the method is 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.
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”.
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: The data reviewed included instances of overwriting, using more than a single
line to mark out and the error corrections were not consistently initialed and dated.
B. Finding: The laboratory needs to increase the traceability documentation of purchased
materials and reagents.
Requirement: 15A NCAC 02H .0805 (a)(7)(K) and (g)(7) requires laboratories to have a
documented system of traceability for the purchase, preparation, and use of all chemicals,
reagents, standards, and consumables. That system must include documentation of the
following information: Date received, Date Opened (in use), Vendor, Lot Number, and
Expiration Date (where specified). 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 and/or manufacturer, lot number, and
expiration date must be retained for primary standards, chemicals, reagents, and materials
used for a period of five years. Consumable materials such as pH buffers, lots of pre-made
standards and/or media, solids and bacteria filters, etc. are included in this requirement.
Ref: NC WW/GW LC Policy.
Comment: The traceability log does not include the date opened or put into use. The
calibration log includes a space for documenting the lot number and expiration date of the
calibration reagents, but the lot numbers are not documented in the reviewed data.
C. Finding: Uncertified data is not documented as such on the benchsheets.
Requirement: All uncertified data must be clearly documented as such on the benchsheet
and on the final report. Ref: 15A NCAC 02H .0805 (e) (3).
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Comment: This applies to Turbidity analyses.
D. Finding: The laboratory benchsheet is lacking required documentation: the sample collector
and the signature or initials of the analyst.
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; the signature or initials of the analyst. 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) and (E).
Comment: The well sampling log identifies the “Sampling Personnel” but does not specify
the sample collector or analyst when more than one person is participating in sampling.
Comment: Please note that the sample analyst must initial or sign the benchsheet when
samples are analyzed. The sample collector must be documented but does not have to
initial or sign the form themselves.
E. Finding: The laboratory benchsheet is lacking required documentation: all manual
calculations.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses and shall consist of: all manual
calculations. 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) (N).
Comment: This Finding applies to Conductivity. The percent recovery must be calculated
and documented to demonstrate that it meets the acceptance criterion.
F. Finding: The laboratory benchsheet is lacking required documentation: permit number.
Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule.
Ref: 15A NCAC 02H .0805 (g) (4).
Requirement: The following must be documented in indelible ink whenever sample analysis
is performed: Facility name, sample site (ID or location), and permit number. Ref: NC
WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen (DO), NC WW/GW
LC Approved Procedure for the Analysis of Specific Conductance (Conductivity), NC
WW/GW LC Approved Procedure for the Analysis of pH and NC WW/GW LC Approved
Procedure for the Analysis of Temperature.
G. Finding: Documentation of the calibration variables for the DO meter does not include all
pertinent data.
Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule.
Ref: 15A NCAC 02H .0805 (g) (4).
Requirement: The following must be documented in indelible ink whenever sample analysis
is performed: Calibration variables (temperature, elevation or barometric pressure [in
mmHg], and salinity). Ref: NC WW/GW LC Approved Procedure for the Analysis of
Dissolved Oxygen (DO).
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Comment: Since the laboratory does not analyze saline samples, a blanket statement may
be added to the benchsheet rather than documenting the Salinity with each calibration. For
example, “Unless otherwise noted, all Dissolved Oxygen calibrations and measurements are
performed at 0 ppt Salinity”.
H. Finding: Values were reported that exceed the method specified accuracy of 0.1 units.
Requirement: 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. Ref: Standard Methods, 4500 H+ B-2011. (6).
Conductivity – EPA 120.1, Rev. 1982 (Aqueous)
Recommendation: The laboratory documents the units of measure as µS/cm on the benchsheet. It
is recommended that the units of measure be changed to µmho/cm on the benchsheet since those
are the units of measure on the reporting form (1 µmho/cm = 1 µS/cm).
I. Finding: The Automatic Temperature Compensator (ATC) check is not being properly
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.
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 LC Approved Procedure for
the Analysis of Specific Conductance (Conductivity). Please submit an updated ATC
verification bracketing the range of compliance samples analyzed with the report
reply.
Comment: The ATC was verified at 10.5 °C, 24.8 °C and 35.3 °C. Sample results below
10.5 °C were included in the data submitted for review.
J. Finding: The laboratory is not analyzing a second-source calibration verification check
standard.
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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 LC Approved Procedure for the Analysis of Specific
Conductance (Conductivity).
Comment: The calibration is verified using the calibration standard. A standard with a
different manufacturer or lot number than the calibration standard must be used for
calibration verification.
Comment: Please note that Conductivity standards may not be diluted.
Dissolved Oxygen – SM 4500 O G-2011 (Aqueous)
K. Finding: The laboratory is not calibrating prior to sample analysis at each sample site or
performing a Post-Analysis Calibration Verification when analyses are performed at multiple
sample sites.
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 LC
Approved Procedure for the Analysis of Dissolved Oxygen (DO).
Temperature – SM 2550 B-2010 (Aqueous)
L. Finding: The annual temperature-measuring device check procedure is not performed
correctly.
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
National Institute of Standards and Technology (NIST) traceable temperature-measuring
device and record all four readings. The readings from both devices must agree within 0.5
ºC. Ref: NC WW/GW LC Approved Procedure for the Analysis of Temperature. Please
submit an updated temperature verification bracketing the range of compliance
samples analyzed with the report reply.
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Comment: The meter was verified at 10.5 °C and 35.3 °C. Sample results below 10.5 °C
were included in the data submitted for review.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks, chains
of custody etc.) and client reports. Data were reviewed for Lassonde Pappas (formerly Clement Pappas)
permit number WQ0004797 and Team Industries Andrews permit number NCG030026 for November
2019 and May 2020. 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 and implementing the Recommendation 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: November 19, 2020
Report reviewed by: Anna Ostendorff Date: November 20, 2020
Certificate Number:5445
Effective Date:1/1/2020
Expiration Date:12/31/2020
Lab Name:Anchor QEA of North Carolina PLLC
Address:231 Haywood Street
Asheville, NC 28801-
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
CONDUCTIVITY
EPA 120.1, Rev. 1982 (Aqueous)
DISSOLVED OXYGEN
SM 4500 O G-2011 (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.