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HomeMy WebLinkAbout#5465_0331_finalA NCDENR North Carolina Department of Environment and Natural Resources Pat McCrory Donald R, van der Vaart Governor Secretary April 15, 2015 5465 S&J Villari Livestock Mr. Gerald L. Matthews 892 Penny Branch Road Warsaw, NC 28398 Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Matthews: Enclosed is a report for the inspection performed on March 31, 2015 by Todd Crawford. 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 and include an implementation date for each corrective action. 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 (919) 733-3908. Attachment cc: Todd Crawford Sincerely, Dana Satterwhite, Environmental Program Supervisor 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.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. #: 5465 Laboratory Name: S & J Villari Livestock Inspection Type: Field Maintenance Inspector Name(s): Todd Crawford Inspection Date: March 31, 2015 Date Report Completed: April 6, 2015 Date Forwarded to Reviewer: April 6, 2015 Reviewed by: Jason Smith Date Review Completed: April 10, 2015 Cover Letter to use: ❑ Insp. Initial ® Insp. Reg. ❑ Insp. No Finding ❑ Insp. CP ❑ Corrected ❑ Insp. Reg. Delay Unit Supervisor/Chemist III: Dana Satterwhite Date Received: 4/13/2015 Date Forwarded to Linda: 4/14/2015 Date Mailed: 4/15/2015 On -Site Inspection Report LABORATORY NAME: WATER QUALITY PERMIT # : ADDRESS: CERTIFICATE #: DATE OF INSPECTION: TYPE OF INSPECTION: AUDITOR(S): LOCAL PERSON(S) CONTACTED: INTRODUCTION: S & J Villari Livestock WQ0016376 892 Penny Branch Rd Warsaw, NC 28398 5465 March 31, 2015 Field Maintenance Todd Crawford Gerald L. Matthews 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 Chemists, Inc. (Certification #94). 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. The laboratory is certified for temperature; however, it is not listed on the discharge permit. The laboratory is considering dropping the parameter from their Certification. The requirement associated with Finding A has been implemented by our program since the last inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation Comment: The laboratory benchsheet was missing the instrument identification for all parameters. The NC WW/GW LC Approved Procedure for the Analysis of pH and NC WW/GW LC Approved Procedure for the Analysis of Temperature documents state: The following must be documented in indelible ink Page 2 #5465 S & J Villari Livestock whenever sample analysis is performed: Instrument Identification. This requirement is a new policy that has been implemented by our program since the last inspection. Notification of acceptable corrective action (i.e., a statement that an updated benchsheet, which was provided by the auditor and includes instrument identifications for all parameters, would be put into use on 4/2/15) was received by email on 4/1/15. No further response is necessary for this finding. Comment: The laboratory needed to increase the documentation of purchased materials and reagents. The Quality Assurance Policies for Field Laboratories document states: 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. An auditor -supplied Lab Supply Receipt Log showing all required documentation for reagents currently in use was filled out and implemented during the inspection. No further response is necessary for this finding. Quality Control Comment: Temperature is being taken in order to document thermal preservation of sub -contract samples and is not reported for compliance monitoring. Recommendation: It is recommended that the digital thermometer be labeled with its correction factor and that factor be applied to any documented temperature readings. Proficiency Testing A. 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: 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. pH — Standard Methods, 4500 H+B-2000 Comment: Environmental sample measurements were not bracketed with calibration and check standard buffers. The pH meter was being calibrated with the 4 and 7 pH buffers. Both buffers were being read as checks. NC WW/GW LC Approved Procedure for the Analysis of pH states: For routine work, use a pH meter accurate and reproducible to 0.1 pH unit with a range of 0 to 14, equipped with a temperature compensation device. Follow all manufacturers' recommendations for the calibration of the meter each analysis day. The meter must be calibrated with at least two buffers. In addition to the calibration standards, the meter must be verified with a third calibration standard. The calibration and check standard buffers must bracket the range of the samples being analyzed. The analyst stated that he would begin calibrating with 4, 7 and 10 pH buffers and checking with the meter calibration with the 7 pH buffer. A new benchsheet was provided by the auditor with spaces to document the calibration in that manner. Notification of acceptable corrective action (i.e., a statement that the updated calibration protocol and benchsheet would be put into use on 4/2/15) was received by email on 4/1/15. No further response is necessary for this finding. B. Finding: Values were reported that exceed the method specified accuracy of 0.1 units. Page 3 #5465 S & J Villari Livestock Requirement: By careful use of a laboratory pH meter with good electrodes, a precision of ±0.02 unit and an accuracy of ±0.05 unit can be achieved. However, ± 0.1 pH unit represents the limit of accuracy under normal conditions, especially for measurement of water and poorly buffered solutions. For this reason, report pH values to the nearest 0.1 pH unit. Ref: Standard Methods, 4500 H+ B-2000, (6). 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 Division of Water Resources. Data were reviewed for January and February, 2015. All data for samples collected on 01/02/2015 were reported as being collected on 01/04/2015. All data for samples collected on 02/04/2015 were reported as being collected on 02/02/2015. 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 and include an implementation date for each corrective action. Report prepared by: Todd Crawford Date: April 6, 2015 Report reviewed by: Jason Smith Date: April 10, 2015