HomeMy WebLinkAbout#576 - 10 - 2011 - FINAL'A' "41A
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
December 2, 2011
576
Ms. Anne Marie Traylor
Environmental Quality Institute
75 Fairview Road, Suite B
Asheville, NC 28803
SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Ms. Traylor:
Dee Freeman
Secretary
Enclosed is a report for the inspection performed on October 19 and 21, 2011 by Jason Smith. I apologize for
the delay in getting this report to you. Where finding(s) are cited in this report, a response is required. Within 30
days of receipt, please supply this office with a written item for item description of how these finding(s) were
corrected. 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 me at 828-296-4677.
Sincerely,
Gary Francies
Unit Supervisor
Laboratory Section
CC: Jason Smith
Gary Francies
Master files
DENR DWQ Laboratory Section NC Wastewater/Groundwater Laboratory Certification Branch
1623 Mail Service Center, Raleigh, North Carolina 27699-1623
Location: 4405 Reedy Creek Road. Raleigh, North Carolina 27607-6445
Phone: 919-733-3908 \ FAX: 919.733-6241
Internet: www.dtivglab.org
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NorthCar®l na
Naturallb,
An Equal Opportunity\ Affirmative Action Employer Customer Service:1-877-623-6748 www.ncwaterquality.org
INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
576
Laboratory Name:
Environmental Quality Institute
Inspection Type:
Municipal Maintenance
Inspector Name(s):
Jason Smith
Inspection Date:
October 19 &21, 2011
Date Report Completed:
November 10, 2011
Date Forwarded to Reviewer: November 10, 2011
Reviewed by:
Jeffrev R. Adams
Date Review Completed:
November 14, 2011
Cover Letter to use: _
Insp. Initial _ Insp. Reg. _ Insp. No Finding _ Insp. CP X Corrected
Unit Supervisor:
Gary Francies
Date Received:
11/14/2011
Date Forwarded to Linda:
12/1/2011
ion M-AWHIM4
LABORATORY NAME:
CERTIFICATE #:
DATE OF INSPECTION:
110:*•721,1&1
Environmental Quality Institute
75 Fairview Road, Suite B
Asheville, NC 28803
576
October 19 and 21, 2011
Municipal Maintenance
Jason Smith
Anne Marie Traylor
This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for the
analysis of environmental samples.
II. GENERAL COMMENTS:
The laboratory maintains voluntary laboratory certification for the analysis of river and lake samples for the
Volunteer Water Information Network (VWIN). Since the previous inspection, the laboratory has moved to a
new facility which is spacious and well maintained. The laboratory has all of the equipment necessary to
perform the analyses.
Comment: Error corrections were not dated when performed. North Carolina Wastewater/Groundwater
Laboratory Certification Policy states: 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-OutCg), 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. This requirement is a new policy that has been implemented by our program since the last
inspection. Notification of acceptable corrective action (i.e., the statement that error corrections will be dated)
was received by e-mail on November 1, 2011. No further response is necessary for this finding.
Comment: The laboratory was not documenting all of the required information to provide traceability. North
Carolina Wastewater/Groundwater Laboratory Certification Policy 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 (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. Notification of acceptable corrective action (i.e., the statement that vendor and expiration date
was added to the chemical receipt log as well as clarifying the source, expiration dates, and volumes used for
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the reagent preparation log) was received by e-mail on November 1, 2011. No further response is
necessary for this finding.
General Laboratory
Comment: The balance is not checked with three weights quarterly. The laboratory checks two weights daily.
The North Carolina Administrative Code, 15A NCAC 2H .0805 (a) (7) (K) states: The analytical balance must
be checked with on class S, or equivalent, standard weight each day used and at least three standard
weights quarterly. The values obtained must be recorded in a log and initialed by the analyst. Notification of
acceptable corrective action (i.e., a statement that three weights are now checked daily) was received by e-
mail on November 1, 2011. No further response is necessary for this finding.
Comment: The laboratory was using a traceable thermometer that was accurate to ± 1 °C to check the
thermometers. Although this is adequate for most thermometers, it is not adequate for the fecal bath
thermometer due to the acceptable temperature range being 44.5 ± 0.2 °C. The North Carolina Administrative
Code, 15A NCAC 2H .0805 (a) (6) (H) states: Each laboratory requesting certification must contain or be
equipped with the following: Glassware, chemicals, supplies, and equipment required to perform all
analytical procedures included in their certification. Notification of acceptable corrective action (i.e., a
statement that a traceable thermometer accurate to ±0.1 °C has been obtained) was received by e-mail on
November 1, 2011. No further response is necessary for this finding.
PH — Standard Methods, 20th edition, 4500-Hi' B
Comment: The laboratory was not documenting units of measure (Standard Units or S.U.). The North
Carolina Administrative Code, 15A NCAC 2H .0805 (a) (7) (H) states: All laboratories must use printed
laboratory bench worksheets that include a space to enter the signature or initials of the analyst, date of
analyses, sample identification, volume of sample analyzed, value from the measurement system, factor and
final value to be reported and each item must be recorded each time samples are analyzed. The date and time
BOD and coliform samples are removed from the incubator must be included on the laboratory worksheet.
Notification of acceptable corrective action (i.e., a statement that units of measure were added to the
benchsheet) was received by e-mail on November 1, 2011. No further response is necessary for this
finding.
Suspended Residue — Standard Method, 20th Edition, 2540 D
Comment:
The laboratory is not basing the reporting limit on the minimum weight gain required by the method.
North Carolina Wastewater/ Groundwater laboratory Certification Policy based upon Standard Methods, 20th
and 21st Editions, 2540 D. (3) (b) states: The minimum weight gain allowed by any approved method is 2.5
mg. Choose sample volume to yield between 2.5 and 200 mg dried residue. This establishes a minimum
reporting value of 2.5 mg/L when 1000 mL of sample is analyzed. If complete filtration takes more than 10
minutes increase filter diameter or decrease sample volume. 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. This requirement is a new policy that has been implemented by our program since the last inspection.
Notification of acceptable corrective action (i.e., the reporting limit is established at 10 mg/L based upon 250
mL of sample) was received by e-mail on November 1, 2011. No further response is necessary for this
finding.
Total Phosphorus — Standard Methods, 20th Edition, 4500-P E
Orthophosphate — Standard Methods, 20th Edition, 4500-P E
Comment: The laboratory was analyzing a laboratory water blank and subtracting the results from all samples.
Standard methods, 20th Edition, 4500-P E. (4) (a) states: Natural color of water generally does not interfere at
the high wavelength used. For highly colored or turbid waters, prepare a blank by adding all reagents except
ascorbic acid and potassium antimonyl tartrate to the sample. Subtract blank absorbance from absorbance of
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each sample. Note that the method does not allow for a laboratory water blank subtraction. Additionally, North
Carolina Wastewater/Groundwater Laboratory Certification Policy states: For analyses requiring a calibration
curve, the concentration of method and reagent blanks must not exceed 50% of the reporting limit, unless
otherwise specified by the reference method. For the data reviewed, Orthophosphate blank values up to 0.02
mg/L and Total Phosphorus blank values up to 0.06 mg/L were observed. The reporting limit for each
parameter is 0.02 mg/L. Notification of acceptable corrective action (i.e., a statement that blank corrections will
no longer be used and the reporting limit will be increased if the contamination cannot be identified) was
received by e-mail on November 1, 2011. No further response is necessary for this finding.
Total Phosphorus — Standard Methods, 20t" Edition, 4500-P E
Orthophosphate — Standard Methods, 201" Edition, 4500-P E
Ammonia Nitrogen — Standard methods, 18t" Edition, 4500-NH3 C
Comment: The laboratory is not analyzing duplicates. The North Carolina Administrative Code, 15A NCAC 2H
.0805 (a) (7) (C) states: Except for Oil and Grease (EPA Method 413.1), settleable solids or where otherwise
specified in an analytical method, analyze five percent of all samples in duplicate to document precision.
Laboratories analyzing less than 20 samples per month must analyze at least one duplicate each month
samples are analyzed. Due to a misunderstanding of the requirements, the laboratory stopped analyzing
duplicates for these parameters when matrix spike analyses began to be performed. Notification of acceptable
corrective action (i.e., a statement that matrix spike duplicates, which North Carolina Wastewater/Groundwater
Laboratory Certification Policy allows in place of sample duplicates, are now analyzed) was received by e-mail
on November 1, 2011. No further response is necessary for this finding.
Copper — EPA Method 200.9
Lead — EPA Method 200.9
Comment: The laboratory did not establish the linear dynamic range after moving to a new facility. EPA
Method 200.9 Rev. 2.2 (1994), Section 9.2.2 states: Linear dynamic range (LDR) - The upper limit of the LDR
must be established for the wavelength utilized for each analyte by determining the signal responses from a
minimum of six different concentration standards across the range, two of which are close to the upper limit of
the LDR. Determined LDRs must be documented and kept on file. The linear calibration range which may be
used for the analysis of samples should be judged by the analyst from the resulting data. The upper LDR limit
should be an observed signal no more than 10% below the level extrapolated from the four lower standards.
The LDRs should be verified whenever, in the judgement of the analyst, a change in analytical performance
caused by either a change in instrument hardware or operating conditions would dictate they be redetermined.
IN LII CILIUI I of acceptable l.or r ec- vIs al.Uon (I.e., submil sslon o LLD al laIyZed VI1 vctOber 28, LU I I ) was
received by e-mail on November 1, 2011. No further response is necessary for this finding.
No paper trail performed.
L 01TrOTRUff of TP
All findings noted during the inspection were adequately addressed prior to the completion of this report.
The inspector would like to thank the staff for its assistance during the inspection and data review process. No
response is required.
Report prepared by: Jason Smith Date: November 10, 2011
Report reviewed by: Jeffrey R. Adams Date: November 14, 2011