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Home My WebLink About#482 - 03 - 2010 - FINALLaboratory Cert. #: Laboratory Name: Inspection Type: Inspector Name(s): Inspection Date: Date Report Completed: Date Forwarded to Reviewer: Reviewed by: 482 James & James Environmental Management, Inc. Commercial Maintenance Jason Smith, Gary Francies February 22 and March 16, 2010 April 9, 2010 April 9, 2010 Tonia Springer April 13.2010 Cover Letter to use: _ Insp. Initial X Insp. Reg. _ Insp. No Finding _ Insp. CP Unit Supervisor: Gary Francies Date Received: 4/13/2010 Date Forwarded to Alberta: 4128/2010^✓��s Date Mailed: , AZ4 2) North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director April 29, 2010 482 Ms. Juanita James James & James Environmental Management, Inc. 3801 Asheville Highway Hendersonville, NC 28791 SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dee Freeman Secretary Enclosed is a report for the inspection performed on February 22 and March 16, 2010 by Mr. Jason Smith and myself. 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 coon of this report by email, or if you have questions or need additional information please contact me at 828-296-4677. Sincerely, Gary Francies Unit Supervisor Laboratory Section CC: Jason Smith DENR DWQ Laboratory Section NC Wastewater/Groundwater Laboratory Certification Branch 1623 Mail Service Center, Raleigh, North Carolina 27699-1623 Location: 4406 Reedy Creek Road. Raleigh, North Carolina 27607-6445 Phone: 919-733-39081 FAX: 919-733-6241 Internet: www,dwglab.org An Equal Opportunity \Affirmative Action Employer Customer Service: 1-877-623-6748 www.ncwaterquallt .org NorlhCarollna Natturall LABORATORY NAME: CERTIFICATE #: � lyll*Q21i!h1:2xstI[QZ TYPE OF INSPECTION: E r- 1. INTRODUCTION: James & James Environmental Management, Inc. 3801 Asheville Highway Hendersonville, NC 28791 482 February 22 and March 16, 2010 Commercial Maintenance Jason Smith and Gary Francies Juanita James, Julie Erb, and Laura Swaringen This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for the analysis of environmental samples. The laboratory was clean and well organized. The facility has all the equipment necessary to perform the analyses. Laboratory personnel communicate well with sample collectors and coordinate sample analyses effectively to manage workload and holding times. Due to a relatively large number of Fecal Coliform reporting errors for the month of July, Surface Water Protection requested a more thorough data review of Fecal Coliform data. It appears that the majority of the errors were in July, which corresponded to a large turnover of operator personnel. The laboratory agreed to amend all affected Discharge Monitoring Reports (DMRs). Findings E and G are new policies that have been implemented by our program since the last inspection. General Laboratory A. Finding: The NIST traceable thermometer used to check the laboratory thermometers expired in December, 2008. Requirement: NIST traceable thermometers used for temperature measurement must be recalibrated in accordance with the manufacturer's recalibration date. If no recalibration date is given, the NIST traceable thermometer must be recalibrated annually. Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy. B. Finding: The laboratory needs to clarify the acceptance criteria for duplicates. Requirement: Each laboratory shall develop and maintain a document outlining the analytical quality control practices used for the parameters included in their certification. Supporting records shall be maintained as evidence that these practices are being effectively carried out. Ref: 15A NCAC 2H .0805 (a) (7). Page 2 #482 James & James Environmental Management, Inc. Comment: The Standard Operating Procedure indicates that Relative Percent Difference (RPD) is used to evaluate precision. The laboratory actually uses a percent difference calculation, dividing the low value by the high value. C. Finding: Uncertified data is not documented as such on the benchsheets or final reports. Requirement: All uncertified data must be clearly documented as such on the benchsheet and on the final report. Ref: 15A NCAC 2H .0805 (e) (3). Documentation Recommendation: Collection and analysis times are currently documented in the operators log book, is recommended that this information be documented on a facility benchsheet. D. Finding: The laboratory maintains a reagent preparation log; however, the preparation of the Total Suspended Solids standard is not documented. 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 (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: North Carolina Wastewater/Groundwater Laboratory Certification Policy. Recommendation: North Carolina Wastewater/Groundwater Laboratory Certification Policy requires Performance Testing (PT) samples to be analyzed in the same manner as environmental samples. Although some facilities have high level (mg/L) Total Residual Chlorine (TRC) limits, the majority of them have low level (pg/L) TRC limits. It is recommended that a low level TRC PT sample be analyzed, since that is the range of the majority of samples. E. Finding: A minimum dried residue weight gain of 1 mg is used to determine the reporting limit. Requirement: Choose sample volume to yield between 2.5 and 200 mg dried residue. If volume filtered fails to meet minimum yield, increase sample volume up to 1 L. If complete filtration takes more than 10 minutes increase filter diameter or decrease sample volume. Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy based upon Standard Methods, 20th and 215t Editions, 2540 D. (3) (b). Comment: Since the publication of the Code of Federal Regulations, Title 40, Part 136; Federal Register Vol. 72, No. 47, March 12, 2007, there is no longer an approved method that allows for a 1 mg weight gain. Currently, the minimum weight gain allowed is 2.5 mg. In instances where the weight gain is less than the required 2.5 mg, the value must be reported as less than the appropriate value based upon the volume used. For example, if 500 mL of sample is analyzed Page 3 #482 James & James Environmental Management, Inc. and < 2.5 mg of dried residue is obtained, the value reported would be < 5 mg/L. The minimum reporting value is now established at 2.5 mg1L based upon a sample volume used of 1000 mL. F. Finding: When pH adjustment is required, the sample pH is adjusted to 6.0-8.5 S.U. Requirement: Neutralize samples containing caustic alkalinity (pH >8.5) or acidity (pH <6.0) to PH 6.5 to 7.5 with a solution of sulfuric acid or sodium hydroxide of such strength that the quantity of reagent does not dilute the sample by more than 0.5%. The pH of dilution water should not be affected by the lowest sample dilution. Always seed samples that have been pH adjusted. Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy based upon Standard Methods, 20t" Edition, 5210 B. (4) (e) (1). G. Finding: A calibration verification standard (mid -range) is not analyzed at the end of the sample run and/or after every tenth sample. Requirement: The calibration blank and calibration verification analyzed initially (i.e., prior to sample analysis), after every tenth standard (mid -range) must be sample and at the end of each sample group to check for carry over and calibration drift. If either fall outside established quality control acceptance criteria, corrective action must be taken (e.g., repeating sample determinations since the last acceptable calibration verification, repeating the initial calibration, etc.). Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy based upon Standard Methods, 20tt' Edition, 1020 B. (10) (c), 3020 B. (2) (b), and 4020 B. (2). Comment: This policy has been implemented by the laboratory; however, due to a misunderstanding, the second source standard was analyzed. The mid -range standard analyzed after every tenth sample and at the end of the run is the same source as the calibration standards. The paper trail consisted of comparing laboratory benchsheets and contract lab reports to DMRs submitted to the North Carolina Division of Water Quality. Data were reviewed for July and August, 2009 for each* operator. A follow-up paper trail investigation performed at the request of the data receiver reviewed Fecal Coliform data for January, 2009 through January, 2010. The following errors were noted: Date Parameter Location Value on Benchsheet Value on DMR 7-21-09 BQD Linville Falls 11.4 mg/L 2.4 mg/L Club Effluent 8-20-09 pH Canterbury Hill/ 7.4 S.U. 7.2 S.U. Pleasant Cove Effluent 4-8-09* Fecal Coliform Pavillion >600 cfu/100 mL >120 cfu/100 mL Effluent 4-30-09 Fecal Coliform Rugby Middle 490 cfu/100 mL 400 cfu/100 mL School Effluent Page 4 #482 James & James Environmental Management, Inc. Date Parameter Location Value on Benchsheet Value on DMR 6-16-09 Fecal Coliform Sliding Rock >600 cfu/100 mL >60 cfu/100 mL Effluent 7-15-09 Fecal Coliform Lake Powhatan >600 cfu/100 mL >60 cfu/100 mL Effluent 7-21-09 Fecal Coliform Brookside 280 cfu1100 mL 200 cfu/100 mL Village Effluent 7-29-09 Fecal Coliform Tyco >870 cfu/100 mL >170 cfu1100 mL Electronics Effluent 7-29-09 Fecal Coliform Ledgestone >600 cfu/100 mL >60 cfu/100 mL Subdivision Effluent 11-9-09 Fecal Coliform Bonworth 440 cfu/100 mL 44 cfu/100 mL Effluent however the DMR was not. In order to avoid questions of legality, the laboratory agreed to submit amended Discharge Monitoring Reports. A copy of this report will be forwarded to the Asheville Regional Office. ZMNNKR• • Correcting the above -cited findings and implementing the recommendations 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: April 9, 2010 Report reviewed by: Tonja Springer Date: April 18, 2010