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HomeMy WebLinkAbout#5374 - 04 - 2012 - FINALBeverly Eaves Perdue Charles Wakild, P. E. Dee Freeman Governor Director Secretary May 22, 2012 5374 Mr. Henry Odom Magnolia Place 1 Arel Loop Hendersonville, NC 28792 Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Odum: Enclosed is a report for the inspection performed on April 19, 2012 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 these finding(s) were corrected. 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. 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 us at 828-296-4677. Sincerely, ca:7 Gary Francies Certification Unit Supervisor Laboratory Section Enclosure 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: 919-733-3908 \ FAX: 919-733-6241 Internet: www.dwglab.org An Equal Opportunity 1 Affirmative Action Employer f INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5374 Laboratory Name: Magnolia Place Inspection Type: Field Maintenance Inspector Name(s): Jason Smith Inspection Date: April 19, 2012 Date Report Completed: May 17, 2012 Date Forwarded to Reviewer: May 18, 2012 Reviewed by: Jeff Adams Date Review Completed: May 18, 2012 Cover Letter to use: _ Insp. Initial X Insp. Reg. _ Insp. No Finding _ Insp. CP _Corrected Unit Supervisor: Gary Francies Date Received: 5/18/2012 Date Forwarded to Linda: 5/22/2012 Date Mailed: LABORATORY NAME: NPDES PERMIT #: ADDRESS: CERTIFICATE #: DATE OF INSPECTION: TYPE OF INSPECTION: AUDITOR(S): LOCAL PERSON(S) CONTACTED: INTRODUCTION: On -Site Inspection Report Magnolia Place NCO071862 1 Arel Loop Hendersonville, NC 28792 5374 April 19, 2012 Field Maintenance Jason Smith Henry Odom This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for the analysis of environmental samples. II. GENERAL COMMENTS: The requirements associated with Findings B, C, D, and E are new policies that have been implemented by our program since the last inspection. r - • - • �� • Documentation Comment: The laboratory was not aware of the requirement to qualify quality control failures on the Discharge Monitoring Report (DMR). No instances were observed.This is a new policy that has been implemented since the last inspection. Quality control failures are mostly associated with 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. A. Finding: The time of collection and analysis is not 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). Page 2 #5374 Magnolia Place 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". B. Finding: Error corrections are not dated. 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-Out®, 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. C. Finding: Proficiency Testing (PT) samples are not documented 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. D. Finding: The preparation of PT samples is not documented. Requirement: 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. Ref: Proficiency Testing Requirements, February 20, 2012, Revision 1.2. E. Finding: The laboratory needs to increase the documentation of purchased materials and reagents. Requirement: All chemicals, reagents, standards and consumables used by the laboratory must have the following information documented: Date Received, 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 and/or 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. Ref: Quality Assurance Policies for Field Laboratories. IV. PAPER TRAIL 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 Magnolia Place (NPDES permit #NC0071862) for May, June, and July, 2011. No transcription errors were detected. The facility appears to be doing a good job of accurately transcribing data. Page 3 #5374 Magnolia Place V. CONCLUSIONS: Correcting the above -cited findings 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: May 17, 2012 Report reviewed by: Jeffrey R. Adams Date: May 18, 2012