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HomeMy WebLinkAbout#5649_02_2015_FINALa RCDENR North Carolina Department of Environment and Natural Resources Pat McCrory Governor April 6, 2015 5649 Ms. Kimberly Jones Jones Environmental 45 Pleasant Court Flat Rock, NC 28731 Donald R. van der Vaart Secretary Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Ms. Jones: Enclosed is a report for the inspection performed on February 23, 2015 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. Attachment cc: Master file Jason Smith Sincerely, Gary Francies, Technical Assistance/Compliance Specialist Division of Water Resources Water Sciences Section INC 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.dwglab.org An Equal Opportunity 1 Affirmative Action Employer INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5649 Laboratory Name: Jones Environmental Inspection Type: Field Commercial Initial Inspector Name(s): Jason Smith Inspection Date: February 23, 2015 Date Report Completed: March 24, 2015 Date Forwarded to Reviewer: March 24, 2015 Reviewed by: Beth Swanson Date Review Completed: March 24, 2015 Cover Letter to use: ® Insp. Initial ❑ Insp. Reg. ❑ Insp. No Finding ❑ Insp. CP ❑ Corrected ❑ Insp. Reg. Delay Unit Supervisor/Chemist III: Gary Francies Date Received: 3/24/2015 Date Forwarded to Linda: 4/6/2015 Date Mailed:%�- On -Site Inspection Report LABORATORY NAME: NPDES PERMIT #: ADDRESS: CERTIFICATE #: DATE OF INSPECTION: TYPE OF INSPECTION: AUDITOR(S): LOCAL PERSON(S) CONTACTED: I. INTRODUCTION: Jones Environmental NCO086070 45 Pleasant Court Flat Rock, NC 28731 5649 February 23, 2015 Field Commercial Initial Jason Smith Kimberly Jones 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: The facility has all the equipment necessary to perform the analyses. Proficiency Testing (PT) samples for the 2015 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, 2015. Contracted analyses are performed by Environmental Testing Solutions, Inc. (Certification #600). 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: Documentation A. 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. 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 was emailed to the facility on February 23, 2015. Implementation of this log will fulfill this requirement. Page 2 #5649 Jones Environmental B. Finding: Data that does not meet all quality control requirements is not qualified on the Discharge Monitoring Report (DMR). Requirement: 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 Discharge Monitoring Report (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. Ref: Quality Assurance Policies for Field Laboratories. Comment: The laboratory was not transcribing data qualifiers from the contract laboratory reports to the DMR. The following example was noted: 7/23/14 BOD footnote: Laboratory control standard was outside established limits. Validity of data is not affected. Proficiency Testing C. Finding: The laboratory is not documenting Proficiency Testing (PT) sample analyses in the same manner as environmental samples. Requirement: All PT sample analyses must be recorded in the daily analysis records as for any environmental sample. This serves as the permanent laboratory record. Ref: Proficiency Testing Requirements, February 20, 2012, Revision 1.2. Comment: This means that the PT analyses must be documented on a benchsheet in the same manner as daily samples. 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. Comment: Dating and initialing the instruction sheet for the preparation of the Total Residual Chlorine (TRC) PT would satisfy the documentation requirement. Total Residual Chlorine — Standard Methods, 4500 CI G-2000 Recommendation: Total Residual Chlorine results are not being reported to the verified reporting limit. Results are only reported down to 25 pg/L; however the meter was verified with a standard analyzed at 20 pg/L. It is recommended that the laboratory report values down to the verified reporting limit of 20 pg/L. IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks, etc.) and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Page 3 #5649 Jones Environmental Division of Water Resources. Data were reviewed for the Justice Academy (NPDES permit #NC0086070) for July, August, and September, 2014. The following errors were noted: Date Parameter Location Value on Benchsheet *Contract Lab Data Value on DMR 9/3/14 Ammonia Effluent *0.10 mg/L <0.10 mg/L 9/10/14 Ammonia Effluent *0.10 mg/L <0.10 mg/L 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 and implementing the recommendation 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 and include an implementation date for each corrective action. Report prepared by: Jason Smith Date: March 24, 2015 Report reviewed by: Beth Swanson Date: March 24, 2015