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