#562.2006-f

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#562
Analytical Environmental Services, Inc.

On-Site Inspection Report

LABORATORY NAME: Analytical Environmental Services, Inc.

ADDRESS: 3785 Presidential Parkway
Atlanta, GA 30340

CERTIFICATE NO: #562

DATE OF INSPECTION: October 02 & 03, 2006

TYPE OF INSPECTION: Maintenance

EVALUATOR: Jeffrey R. Adams and Tony Hatcher

LOCAL PERSON(S) CONTACTED: Douglas Mendrala, Greg Jones, Mehmet Yildirim

I. INTRODUCTION:

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 is spacious and well equipped. All facilities and equipment are well maintained. Records
are well kept and most data looked good. Some further quality control procedures need to be
implemented.

III. DEFICIENCIES, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:

GENERAL:

NOTE: Whenever a certified commercial laboratory refers or subcontracts samples to another certified
laboratory for analyses, the referring laboratory must supply the date and time samples were collected to
insure holding times are met. Subcontracted samples must clearly indicate the State of North Carolina as
the collection site on all record transcripts. Laboratories may subcontract sample fractions, extracts,
leachates and other sample preparation products provided that all Rules and requirements of 15A NCAC
02H .0800 are documented. The initial client requesting the analyses must receive the original or a
copy of the report made by the laboratory that performs the analyses.
Ref: 15A NCAC 02H .0805 (e) 2.

NOTE: Records which are stored on electronic media must be maintained and supported in the laboratory
by all hardware and software necessary for immediate data retrieval and review. Ref: 15A NCAC 02H
.0805 (7) (G).

NOTE: At any time a laboratory receives samples which do not meet sample collection, holding time, or
preservation requirements, (i.e. organic trip blanks, field blanks, mercury trip blanks, temperature
blanks, etc.) the laboratory must notify the sample collector or client and secure another sample if
possible. If another sample cannot be secured the original sample may be analyzed, but the results
reported must be qualified with the nature of the infraction(s) and the laboratory must notify the State
Laboratory about the infraction(s). The notification must include a statement indicating corrective action
taken to prevent the problem for future samples. Ref. 15A NCAC 2H .0805 (a) (7) (n)
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Analytical Environmental Services, Inc.

Walkthrough:

(A). COMMENT: The laboratory personnel are not always making corrections to the data as required.

REQUIREMENT: If a mistake is made in data recording, the mistake must be removed by making a
single line through the incorrect entry, recording the correct entry beside mistake, and initialing and
dating the error. Ref: SW 846 Sept. 1994 Test Methods for Evaluating Wastes, Chapter One pg. 13

(B). COMMENT: Temperature trip blanks are not always in cooler.

REQUIREMENT: Replicate field reagent blanks (FRB) must be handled along with each sample set,
which is composed of the samples collected from the same general sampling site at approximately the
same time. To monitor for possible contamination, a trip blank prepared with organic-free water must be
carried throughout the sampling, storage, and shipping process. Ref: Leaking Underground Fuel Tank
Field Manual: Guidelines for Site Assessment, Cleanup, and Underground Storage Tank Closure
Oct. 1989 State of California LUST Task Force.

REQUIREMENT: Several instances of accidental sample contamination have been attributed to
diffusion of volatile organics through the septum seal into the sample bottle during shipment and
storage. Trip blanks must be used to monitor for this problem. Ref: SW846, Method 8011, Section 3.2.

RECOMMENDATION: It is highly recommended that the laboratory emphasize to the customer the
importance and need to include a “Temperature Blank” with each set of samples (1 per cooler) or the
laboratory should use Infra-red thermometers, as these can be used without contaminating the sample.
This is to insure adequate and required transport temperatures and the overall integrity of the samples
received.

(1) DEFICIENCY: Lab is using a temperature range of 4 ± 2ºC for sample receipt, sample storage units,
and refrigerators.

REQUIREMENT: The acceptable temperature range of samples during storage and for stored sample
extracts, is 1.0 - 4.4ºC. Ref: Federal Register, July 1, 1995; 40 CFR 136; Table II. Required
Containers, Preservation Techniques, and Holding Times. EPA letters of January and February
1995.

BOD:

(2) DEFICIENCY: Bubbles were present in some of the incubating bottles.

REQUIREMENT: Bubbles must not be present in the incubating BOD samples. Fill bottles with enough
dilution water, seeded if necessary, so that insertion of stopper will displace all air, leaving no bubbles.
Ref: Standard Methods 18th Edition, Method 5210 B. page 5-5.

(C) COMMENT: The laboratory is not analyzing a 2% GGA standard.

REQUIREMENT: A 2% GGA standard must be analyzed each time. This standard must have a true
value of 198 ± 30.5 mg/L. If the measured BOD for a GGA standard is outside accepted control limit
range, you may reject or qualify (if all other factors are acceptable) tests made with that seed and
dilution water. Ref: Standard Methods, 18th Edition - Method 5210.

RECOMMENDATION: Two 2% GGA standards should be analyzed each time.

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Analytical Environmental Services, Inc.

NOTE: The laboratory is analyzing a 1.5 and 2.4 % GGA (5 & 8 ml), but not a 2% (6 ml). The
laboratory cites (2) different concentrations are being required by NELAC. It is required that at least (1)
must be a 2% GGA standard. It was recommended that to meet the NELAC requirements, (1) of the
GGA Standards can be the required 2% concentration.

SULFIDE:
(3) DEFICIENCY: Samples are not being duplicated at the required frequency.

REQUIREMENT: Five percent of all samples must be analyzed in duplicate. If less than 20 samples are
being analyzed per month then one duplicate per month must be analyzed. Duplicates must be of the
same volume, not different volumes. Duplicates must not vary by more than three times the standard
variation for the method. If the variance is more than three times the standard deviation of the method or
falls outside of established control limits, whichever is lower, corrective action must be taken. Our program
requires analysis of duplicate samples to establish precision. Ref: NCAC 15A 2H .0805 (a) (7) (C)

(D). COMMENT: Procedures being performed in the laboratory do not agree with laboratorys SOP.

REQUIREMENT: The SOP must be revised to reflect what occurs in the laboratory.

TOC:

(E) COMMENT: No bottle blank is being analyzed for each lot of bottles.
REQUIREMENT: Check bottle blanks with each set of sample bottles to determine effectiveness or
necessity of cleaning. Ref: Standard Methods 20th Edition, Method 5310 B. C. 4. d.

IV. PAPER TRAIL INVESTIGATION:

A paper trail was performed during the inspection. This consisted of comparing data with the
values obtained on laboratory bench worksheets and final data reported to the client. Two (4) data packs
were reviewed for some parameters from November 17, 2005, February 06, August 30 and September 09,
2006. No data transcription or reporting errors were detected. All calculations and data reviewed appeared
accurate and well documented.

V. CONCLUSIONS:

Correcting the above cited deficiencies and comments and implementing the requirements and
recommendations will help this lab to produce quality data and meet certification requirements. Please
respond to the numbered deficiencies and lettered comments.

Report prepared by: Jeffrey R. Adams
Date: November 28, 2006
Report reviewed by: Tony Hatcher
Date: December 15, 2006