HomeMy WebLinkAbout#5637_06_2014_FINALVA
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ACDERRk
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
July 21, 2014
5637
Mr. Joe Harrell II
Gates County Schools
PO Box 125
Gatesville, NC 27538
John E, Skvarla, III
Secretary
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Harrell:
Enclosed is a report for the inspection performed on June 25, 2014 by Nick Jones. 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.
Attachment
cc: Nick Jones
Master File
Sincerely,
Gary Francies, Technical Assistance/Compliance Specialist
Division of Water Resources
Water Sciences 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
Phone: 919-733-39081 FAX: 919-733-6241
Internet: www,4LA b.orq
An Equal Opportunity 1Affirmative Action Employer
INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5637
Laboratory Name:
Gates County Schools
Inspection Type:
Field Municipal
Inspector Name(s):
Nick Jones
Inspection Date:
June 25, 2014
Date Report Completed:
July 8, 2014
Date Forwarded to Reviewer:
July 8, 2014
Reviewed by:
Tonia Springer
Date Review Completed:
July 14, 2014
Cover Letter to use:
® Insp. Initial ❑ Insp. Reg.
❑ Insp. No Finding ❑ Insp. CP
❑ Corrected
Unit Supervisor/Chemist III: Gary Francies
Date Received: 7/17/2014
Date Forwarded to Linda: 7/21/2012
Date Mailed: ` 14 ( 114 LC.
On -Site Inspection Report
LABORATORY NAME: Gates County Schools
NPDES PERMIT #: NC0043974, NC0033782, NCO033804
ADDRESS: PO Box 125
Gatesville, NC 27538-
CERTIFICATE #: 5637
DATE OF INSPECTION: June 25, 2014
TYPE OF INSPECTION: Field Initial
AUDITOR: Nick Jones
LOCAL PERSON(S) CONTACTED: Joe Harrell II and Gary Stevens
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 2H .0800 for the analysis of
environmental samples.
II. GENERAL COMMENTS:
This was the laboratory's first inspection since its' initial certification on September 23,
2013. The laboratory's records were organized and easily retrievable. Laboratory
personnel communicate well with sample collectors and coordinate sample analyses
effectively to manage workload.
Proficiency Testing (PT) samples for the 2014 proficiency testing calendar year have not
yet been analyzed. The laboratory is reminded that these results must be submitted to this
office directly from the vendor by September 30, 2014.
Contracted analyses are performed by Environment 1, Inc. (Certification #10).
Current quality assurance policies for Field Laboratories and approved procedures for
the analysis of the facility's currently certified parameters were provided at the time of
the inspection.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Quality Control
A. Finding: The laboratory needs to increase the documentation of purchased
materials and reagents.
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#5638 Gates County Schools
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. Consumable
materials such as PH buffers and lots of pre -made standards are included in this
requirement. Ref: Quality Assurance Policies for Field Laboratories.
Comment: An example traceability log sheet that documents all required
traceability information was supplied by the auditor during the inspection.
B. Finding: Error corrections are not performed properly (overwriting).
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.
Documentation
C. Finding: The laboratory benchsheets were missing the following:
• units of measure — pH, DO and Temperature
• instrument ID — pH, DO and Temperature
• facility name - pH
• meter calibration - pH
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 bench sheets must provide a
space for the signature or initials of the analyst, and proper units of measure for
all analyses. Ref: 15A NCAC 02H .0805 (g) (1).
Requirement: Documentation: The following must be documented in indelible
ink whenever sample analysis is performed. 3. Sample site including facility
name and location, ID, etc. 5. Meter calibration and meter calibration time. 10.
Report all data values to the nearest 0.1 PH unit. 12. Instrument identification.
Ref: NC WW/GW LC Approved Procedure for the Analysis of pH.
Requirement: Documentation: The following must be documented in indelible
ink whenever sample analysis is performed. 1. Date and time of sample
collection. 7. All data must be reported in mg/L. 8. Instrument identification. Ref:
NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen.
Requirement: Documentation: The following must be documented in indelible
ink whenever sample analysis is performed. 6. All data must be reported in °C. 9.
Thermometer/ Instrument identification. Ref: NC WW/GW LC Approved
Procedure for the Analysis of Temperature.
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#5638 Gates County Schools
Comment: At the request of the laboratory, the inspector prepared a benchsheet
that contains all of the required pertinent data. The inspector sent the benchsheet
to the lab via email on 7/7/2014.
PH — Standard Methods, 4500 H+B-2000
D. Finding: The laboratory's pH meter does not meet the minimum criteria required
by the method.
Requirement: Each facility must have glassware, chemicals, supplies, equipment,
and a source of distilled or deionized water that will meet the minimum criteria of
the approved methodologies. Ref: 15A NCAC 02H .0805 (a) (6) (H).
Requirement: Report all data values to the nearest 0.1 pH unit. Ref: NC
WW/GW LC Approved Procedure for the Analysis of pH.
Comment: Although the pH meter read to 0.1 S.U. it is only accurate to 1 S.U. For
the meter to be accurate to 0.1 S.U. it must be able to read to 0.01 S.U. The meter
does not automatically properly round values to the nearest 0.1 S.U.
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
Resources. Data were reviewed for Gates County Schools (NPDES permit #s
NC0043974, NC0033782, NC0033804) for April 2014. No transcription errors were
detected. The facility appears to be doing a good job of accurately transcribing data.
However, the laboratory has not been correctly reporting Total Nitrogen. The lab has
been reporting Total Kjeldahl Nitrogen (TKN) as Total Nitrogen. Total Nitrogen is
calculated as the sum of TKN and Nitrate+Nitrite.
In order to avoid questions of legality, it is recommended that you contact the
appropriate Regional Office for guidance as to whether an amended Discharge
Monitoring Report will be required. A copy of this report will be made available to the
Regional Office.
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: Nick Jones Date: July 8, 2014
Report reviewed by: Tonja Springer Date: July 14, 2014