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NC Department of Environmental Quality | Division of Water Resources | Laboratory Certification Branch
4405 Reedy Creek Road | 1623 Mail Service Center | Raleigh, North Carolina 27699-1623
919-733-3908
August 30, 2023
5586
Mr. Lee Garner
Reed Gold Mine
9621 Reed Mine Road
Midland, NC 28107-
Subject: North Carolina Wastewater/Groundwater Laboratory Certification Branch (NC
WW/GW LCB) Maintenance Inspection
Dear Mr. Garner:
Enclosed is a report for the inspection performed on July 19, 2023 by Michael Cumbus. I apologize
for the delay in getting this report to you. Where Finding(s) are cited in this report, a response is
required. Within thirty days, please supply this office with a written item for item description of
how these Finding(s) were corrected. Please describe the steps taken to prevent recurrence 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
02H .0800.
A copy of the laboratory’s Certified Parameter List at the time of the audit is attached. This list will
not reflect any changes made during the audit. Copies of the checklists completed during the
inspection may be requested from this office. Thank you for your cooperation during the
inspection. If you have questions or need additional information, please contact me at (919) 733-
3908 Ext. 259.
Sincerely,
Beth Swanson
Technical Assistance & Compliance Specialist
Division of Water Resources
Attachment
cc: Michael Cumbus, Todd Crawford, #5586
On-Site Inspection Report
LABORATORY NAME: Reed Gold Mine
WATER QUALITY PERMIT #: WQ0006946
ADDRESS: 9621 Reed Mine Road
Midland, NC 28107
CERTIFICATE #: 5586
DATE OF INSPECTION: July 19, 2023
TYPE OF INSPECTION: Field Maintenance
AUDITOR(S): Michael Cumbus
LOCAL PERSON(S) CONTACTED: Lee Garner
I.INTRODUCTION:
This laboratory was inspected by a representative of the North Carolina Wastewater/Groundwater Laboratory
Certification Branch (NC WW/GW LCB) to verify its compliance with the requirements of 15A NCAC 02H
.0800 for the analysis of compliance monitoring samples.
II.GENERAL COMMENTS:
The facility is neat and well organized and has all the equipment necessary to perform the analyses. The
analyst was forthcoming and responded well to suggestions from the auditor.
The facility where data is transcribed to the reporting form is poorly illuminated, which may contribute to
transcription errors.
All required Proficiency Testing (PT) Samples have been analyzed for the 2023 PT Calendar Year and the
graded results were 100% acceptable.
Any time changes are made to laboratory procedures, Quality Assurance (QA) and/or Standard Operating
Procedure (SOP) document(s) must be updated and relevant staff retrained. Staff must acknowledge that
they have read and understand the changes as part of the documented training program. The same
requirements apply when changes are made in response to Findings, Recommendations or Comments
listed in this report, to ensure the methods are being performed as stated, references to methods are
accurate, and the QA and SOP documents are in agreement with each approved practice, test, analysis,
measurement, monitoring procedure or regulatory requirement being used in the laboratory. In some
instances, the laboratory may need to create an SOP to document how new functions or policies will be
implemented. Revisions to the SOPs, based on the Findings, Comments and Recommendations
within this report must be submitted to this office by November 30, 2023.
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The laboratory is reminded that SOPs are required to be reviewed at least every two years and are intended
to describe procedures exactly as they are to be performed. Use of the word “should” is not appropriate when
describing requirements (e.g., Quality Control (QC) frequency, acceptance criteria, etc.). Evaluate all SOPs
for the proper use of the word “should”.
Contracted analyses are performed by K & W Laboratories (Certification #559).
Approved Procedure documents for the analysis of the facility’s currently certified Field Parameters were
provided at the time of the inspection.
III.FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
A.Finding: Error corrections are not properly performed.
Requirement: All documentation errors shall 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-Out®, correction tape, or similar products designed to obliterate
documentation are not to be used; instead the correction shall be written adjacent to the error.
The correction shall be initialed by the responsible individual and the date of change
documented. Ref: 15A NCAC 02H .0805 (g) (1).
B.Finding: The laboratory has not fully developed and implemented a documented training
program.
Requirement: Each laboratory shall develop and implement a documented training program
that includes the following: that staff have the education, training, experience, or demonstrated
skills needed to generate quality control results within method-specified limits and that meet
the requirements of these Rules; that staff have read the laboratory quality assurance manual
or applicable Standard Operating Procedures; that staff have obtained acceptable results on
Proficiency Testing Samples pursuant to Rule .0803(1) of this Section or other demonstrations
of proficiency (e.g., side-by-side comparison with a trained analyst, acceptable results on a
single-blind performance evaluation sample, an initial demonstration of capability study
prescribed by the reference method). Ref: 15A NCAC 02H .0805 (g) (5).
Comment: The laboratory SOPs do not specify what is required to meet each training
requirement for compliance sample analysis. The following items must be addressed to
ensure that current and future employees are able to produce reliable data:
•The TRC SOP Section 15.1 says “Include education, training, experience and/or
demonstrated skills required for the position” but does not specify what would meet
this requirement (e.g., wastewater operator certification, prior laboratory experience,
etc.).
•The TRC SOP Section 15.3 and the pH SOP Section 15.2 list the options for
Demonstration of Proficiency (DOP). The primary option is a PT result graded
Acceptable, but also includes alternative options such as an Initial Demonstration of
Capability or side by side analysis with an established analyst. The SOP must clearly
state which options are in practice, as well as state the acceptance criteria for the
alternative DOPs.
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C.Finding: All original records are not being maintained for five years.
Requirement: All analytical records, including original observations and information
necessary to facilitate historical reconstruction of the calculated results, shall be maintained
for five years. Ref: 15A NCAC 02H .0805 (g) (1).
Comment: The testing data is initially written on a piece of paper, transported back to the
laboratory, and transferred to an electronic copy of the benchsheet which is then printed. This
original paperwork is then discarded.
D.Finding: The laboratory is not documenting all traceability information for purchased
materials, reagents and standards.
Requirement: 15A NCAC 02H .0805 (a) (7) (K) and (g) (7) requires laboratories to have a
documented system of traceability for the purchase, preparation, and use of all chemicals,
reagents, standards, and consumables. That system must include documentation of the
following information: 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. Ref:
NC WW/GW LCB Traceability Documentation Requirements for Chemicals, Reagents,
Standards and Consumables Policy.
Comment: Dates received and opened were written on the DPD powder pillow bulk container
and pH buffer bottles, as required. While this can provide a traceability link to analyses while
the chemicals are still in use, that link is lost once the bottles are discarded.
E.Finding: The laboratory benchsheet for pH and Total Residual Chlorine (TRC) is lacking
required documentation: the date of sample collection.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data shall
be traceable to the associated sample analyses and shall consist of: the date and time of
sample collection. Each item shall be recorded each time samples are analyzed. Analyses
shall conform to methodologies found in Subparagraph (a)(1) of this Rule. Ref: 15A NCAC
02H .0805 (g) (2) (F).
Comment: A blanket statement that the dates of collection and analysis are the same would
satisfy the requirement.
F. Finding: The laboratory benchsheet does not correctly document the acceptance criterion of
the TRC Daily Check Standard.
Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref:
15A NCAC 02H .0805 (g) (4).
Requirement: The value obtained for the Daily Check Standard must read within ±10% of
the true value of the Daily Check Standard for standards ≥50 μg/L. Ref: NC WW/GW LCB
Approved Procedure for the Analysis of Total Residual Chlorine (DPD Colorimetric by SM
4500 Cl G-2011).
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#5586 Reed Gold Mine
Comment: The TRC Daily Check Standard has an assigned True Value of 0.20 mg/L. The
benchsheet lists two acceptance ranges; ±10% of the true value and 0.20 to 0.20 mg/L.
However, the correct range is 0.18 to 0.22 mg/L. No data were examined where the Daily
Check Standard did not meet the required acceptance criterion.
Proficiency Testing
Recommendation: The laboratory performs the analysis of PT samples at K & W Laboratories after
the annual verifications are performed. K & W provides glassware, pipettes and reagent water. It is
recommended that the laboratory add this information to each SOP’s PT section.
G.Finding: The laboratory is not documenting the preparation of PT Samples.
Requirement: PT Samples received as ampules are diluted according to the Accredited PT
Sample Provider’s instructions. It is important to remember to document the preparation of PT
Samples in a traceable log or other traceable format. The diluted PT Sample then becomes a
routine Compliance Sample and is added to a routine sample batch for analysis. No
documentation is needed for whole volume PT Samples which require no preparation,
however the instructions must be maintained. Ref: Proficiency Testing Requirements, January
1, 2023, Revision 6, Section 3.6.
Comment: Dating and initialing the instruction sheet for each prepared PT Sample would
satisfy the documentation requirement.
Quality Assurance/Quality Control
H.Finding: The laboratory is not evaluating the recovery of the pH Check Standard Buffer to
demonstrate the analytical process is in control and the established acceptance criterion is
met.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data shall
be traceable to the associated sample analyses and shall consist of: the quality control
assessments. Ref: 15A NCAC 02H .0805 (g) (2) (O).
Comment: The benchsheet has a footnote that states that the check standard buffer must
read within ± 0.1 S.U. of the buffer’s true value, but it lacks an acknowledgement that this
requirement has been met.
Chlorine, Total Residual – Standard Methods, 4500 Cl G-2011 (Aqueous)
I.Finding for Immediate Response: The laboratory failed to perform corrective action when
the verification of the TRC meter was outside the recovery acceptance criteria.
Requirement: If quality control results fall outside established limits or indicate an analytical
problem, the laboratory shall identify the Root Cause of the failure. The problem shall be
resolved through corrective action, the corrective action process documented, and any
samples involved shall be reanalyzed, if possible. If the sample cannot be reanalyzed, or if
the quality control results continue to fall outside established limits or indicate an analytical
problem, the results shall be qualified as such. Ref: 15A NCAC 02H .0805 (g) (8).
Requirement: If the factory-set readings vary by more than the stated acceptance criteria,
the stored calibration program must not be used for compliance monitoring until
troubleshooting is carried out to determine and correct the source of error. Ref: NC WW/GW
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#5586 Reed Gold Mine
LCB Approved Procedure for the Analysis of Total Residual Chlorine (DPD Colorimetric by
SM 4500 Cl G-2011).
Requirement: The calibration standard values obtained must not vary by more than ±10%
from the known value for standard concentrations greater than or equal to 50 μg/L and must
not vary by more than ±25% from the known value for standard concentrations less than 50
μg/L. Ref: NC WW/GW LCB Approved Procedure for the Analysis of Total Residual Chlorine
(DPD Colorimetric by SM 4500 Cl G-2011).
Comment: The Hach Pocket Colorimeter II currently in use was sent for the annual factory
curve verification on May 25, 2023. The report issued by the contract laboratory notes that the
2.0 mg/L standard had a recovery of 87%, which does not meet the acceptance criterion of ±
10%. A Notice of Finding for Immediate Response (NOFIR) was issued on July 25, 2023. In
an email dated July 26, 2023, the laboratory agreed to immediately take the instrument out of
service, and put their backup instrument, which has a passing calibration curve verification,
into use until the issue is resolved. The laboratory submitted a revised benchsheet on August
21, 2023 with the instrument ID updated to the meter currently in use. No further response
is necessary for this Finding.
J. Finding: The laboratory is not documenting the results of the Method Blank when using
laboratory-prepared standards.
Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref:
15A NCAC 02H .0805 (g) (4).
Requirement: The following must be documented in indelible ink whenever sample analysis
is performed: Value obtained for the Method Blank, if applicable (verification of ≤ ½
concentration of the lowest calibration curve, or calibration curve verification, standard). Ref:
NC WW/GW LCB Approved Procedure for the Analysis of Total Residual Chlorine (DPD
Colorimetric by SM 4500 Cl G-2011).
Comment: Proficiency Testing samples are included in this requirement.
pH – Standard Methods, 4500 H+B-2011 (Aqueous)
K.Finding: Values were reported that exceed the method specified accuracy of 0.1 units.
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-2011. (6).
Comment: Per PT Vendor instructions, the PT Sample results should be reported to two
decimal places, which is an exception to the requirement for Compliance Samples.
Recommendation: The laboratory currently reports pH sample results to two decimal places.
It is recommended that the laboratory continue to measure and document sample results on
the benchsheet to two decimal places, and to round to the nearest 0.1 S.U. when reporting
results on the Non-Discharge Monitoring Report (NDMR).
Reporting
L. Finding: The laboratory is producing Uncertified Data without reporting it as such.
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Requirement: “Uncertified Data" means any analytical result, including the Supporting
Records, obtained using a method or procedure that is not acceptable to the State Laboratory
pursuant to these Rules; analytical results produced by a laboratory for an analysis not within
the scope of the rules of this Section; or analytical results produced by a laboratory without
proper Certification. Ref: 15A NCAC 02H .0803 (35).
Requirement: All Uncertified Data shall be documented as such on the benchsheet and on
the final report. Ref: 15A NCAC 02H .0805 (e) (3).
Comment: At the time of the inspection, the laboratory was analyzing Temperature and
reporting the results on the NDMR without qualifying the data as Uncertified. Upon review of
the permit, it was noted that Temperature is not a required parameter. In an email dated July
24, 2023, staff agreed to immediately cease analyzing and reporting Temperature for the
permitted site. No Further Response is necessary for this Finding.
M.Finding: Values less than the established reporting limit for TRC are being reported on the
NDMR.
Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref:
15A NCAC 02H .0805 (g) (4).
Requirement: For all calibration options, the range of standard concentrations must bracket
the permitted discharge limit concentration, the range of sample concentrations to be analyzed
and anticipated PT Sample concentrations. One of the standards must have a concentration
less than the permitted Daily Maximum Limit. The lower reporting limit concentration is equal
to the lowest standard concentration. Sample concentrations that are less than the lower
reporting limit must be reported as a less-than value. Ref: NC WW/GW LCB Approved
Procedure for the Analysis of Total Residual Chlorine (DPD Colorimetric by SM 4500 Cl G-
2011).
Comment: The lowest standard concentration used to verify the factory pre-set curve is 0.1
mg/L. Therefore, any value less than this concentration must be reported as < 0.1 mg/L.
IV.PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks, etc.) and
contract laboratory reports to NDMRs submitted to the North Carolina Division of Water Resources. Data
were reviewed for Reed Gold Mine (Water Quality permit # WQ0006946) for January, February, March,
April and May 2023. The following errors were noted:
Date Parameter Location Value on
Benchsheet Value on NDMR
5/2/2023 pH Effluent 6.35 S.U. 6.53 S.U.
4/25/2023 TRC Effluent 0.05 mg/L 0.26 mg/L
3/7/2023 pH Effluent 6.66 S.U. 6.56 S.U.
3/7/2023 TRC Effluent 0.34 mg/L 0.54 mg/L
2/28/2023 pH Effluent 6.7 S.U. 6.71 S.U.
2/14/2023 pH Effluent 7.06 S.U. 7 S.U.
1/11/2023 pH Effluent 6.74 S.U. 6.71 S.U.
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To avoid questions of legality, it is recommended that you contact the appropriate Regional Office for
guidance as to whether amended NDMRs 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(s) will help this laboratory to
produce quality data and meet Certification requirements. The inspector would like to thank the staff for
their assistance during the inspection and data review process. Please respond to all Findings and
include supporting documentation, implementation dates and steps taken to prevent recurrence
for each corrective action.
Report prepared by: Michael Cumbus Date: July 28, 2023
Report reviewed by: Tom Halvosa Date: August 4, 2023
Certificate Number:5586
Effective Date:1/1/2023
Expiration Date:12/31/2023
Lab Name:Reed Gold Mine
Address:9621 Reed Mine Road
Midland, NC 28107-
North Carolina Wastewater/Groundwater Laboratory Certification
Certified Parameters Listing
Date of Last Amendment:
The above named laboratory, having duly met the requirements of 15A NCAC 2H.0800, is hereby certified for the measurement of the parameters listed below.
CERTIFIED PARAMETERS
INORGANIC
CHLORINE, TOTAL RESIDUAL
SM 4500 Cl G-2011 (Aqueous)
pH
SM 4500 H+B-2011 (Aqueous)
This certification requires maintance of an acceptable quality assurance program, use of approved methodology, and satisfactory performance on evaluation samples. Laboratories are subject to civil penalties and/or decertification for infractions
as set forth in 15A NCAC 2H.0807.