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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 O 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 Page 2 #576 Environmental Quality Institute 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 Page 3 #576 Environmental Quality Institute 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