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HomeMy WebLinkAbout#5637_06_2014_FINALVA ip ACDERRk North Carolina Department of Environment and Natural Resources Pat McCrory Governor July 21, 2014 5637 Mr. Joe Harrell II Gates County Schools PO Box 125 Gatesville, NC 27538 John E, Skvarla, III Secretary Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Harrell: Enclosed is a report for the inspection performed on June 25, 2014 by Nick Jones. 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. 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 (828) 296-4677. Attachment cc: Nick Jones Master File Sincerely, Gary Francies, Technical Assistance/Compliance Specialist 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,4LA b.orq An Equal Opportunity 1Affirmative Action Employer INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5637 Laboratory Name: Gates County Schools Inspection Type: Field Municipal Inspector Name(s): Nick Jones Inspection Date: June 25, 2014 Date Report Completed: July 8, 2014 Date Forwarded to Reviewer: July 8, 2014 Reviewed by: Tonia Springer Date Review Completed: July 14, 2014 Cover Letter to use: ® Insp. Initial ❑ Insp. Reg. ❑ Insp. No Finding ❑ Insp. CP ❑ Corrected Unit Supervisor/Chemist III: Gary Francies Date Received: 7/17/2014 Date Forwarded to Linda: 7/21/2012 Date Mailed: ` 14 ( 114 LC. On -Site Inspection Report LABORATORY NAME: Gates County Schools NPDES PERMIT #: NC0043974, NC0033782, NCO033804 ADDRESS: PO Box 125 Gatesville, NC 27538- CERTIFICATE #: 5637 DATE OF INSPECTION: June 25, 2014 TYPE OF INSPECTION: Field Initial AUDITOR: Nick Jones LOCAL PERSON(S) CONTACTED: Joe Harrell II and Gary Stevens I. INTRODUCTION: 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: This was the laboratory's first inspection since its' initial certification on September 23, 2013. The laboratory's records were organized and easily retrievable. Laboratory personnel communicate well with sample collectors and coordinate sample analyses effectively to manage workload. Proficiency Testing (PT) samples for the 2014 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, 2014. Contracted analyses are performed by Environment 1, Inc. (Certification #10). 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. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Quality Control A. Finding: The laboratory needs to increase the documentation of purchased materials and reagents. Page 2 #5638 Gates County Schools Requirement: 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. Ref: Quality Assurance Policies for Field Laboratories. Comment: An example traceability log sheet that documents all required traceability information was supplied by the auditor during the inspection. B. Finding: Error corrections are not performed properly (overwriting). Requirement: 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-Out®, 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. Ref: Quality Assurance Policies for Field Laboratories. Documentation C. Finding: The laboratory benchsheets were missing the following: • units of measure — pH, DO and Temperature • instrument ID — pH, DO and Temperature • facility name - pH • meter calibration - pH Requirement: Data pertinent to each analysis must be maintained for five years. Certified Data must consist of date collected, time collected, sample site, sample collector, and sample analysis time. The field bench sheets must provide a space for the signature or initials of the analyst, and proper units of measure for all analyses. Ref: 15A NCAC 02H .0805 (g) (1). Requirement: Documentation: The following must be documented in indelible ink whenever sample analysis is performed. 3. Sample site including facility name and location, ID, etc. 5. Meter calibration and meter calibration time. 10. Report all data values to the nearest 0.1 PH unit. 12. Instrument identification. Ref: NC WW/GW LC Approved Procedure for the Analysis of pH. Requirement: Documentation: The following must be documented in indelible ink whenever sample analysis is performed. 1. Date and time of sample collection. 7. All data must be reported in mg/L. 8. Instrument identification. Ref: NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen. Requirement: Documentation: The following must be documented in indelible ink whenever sample analysis is performed. 6. All data must be reported in °C. 9. Thermometer/ Instrument identification. Ref: NC WW/GW LC Approved Procedure for the Analysis of Temperature. Page 3 #5638 Gates County Schools Comment: At the request of the laboratory, the inspector prepared a benchsheet that contains all of the required pertinent data. The inspector sent the benchsheet to the lab via email on 7/7/2014. PH — Standard Methods, 4500 H+B-2000 D. Finding: The laboratory's pH meter does not meet the minimum criteria required by the method. Requirement: Each facility must have glassware, chemicals, supplies, equipment, and a source of distilled or deionized water that will meet the minimum criteria of the approved methodologies. Ref: 15A NCAC 02H .0805 (a) (6) (H). Requirement: Report all data values to the nearest 0.1 pH unit. Ref: NC WW/GW LC Approved Procedure for the Analysis of pH. Comment: Although the pH meter read to 0.1 S.U. it is only accurate to 1 S.U. For the meter to be accurate to 0.1 S.U. it must be able to read to 0.01 S.U. The meter does not automatically properly round values to the nearest 0.1 S.U. IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing field testing records and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Resources. Data were reviewed for Gates County Schools (NPDES permit #s NC0043974, NC0033782, NC0033804) for April 2014. No transcription errors were detected. The facility appears to be doing a good job of accurately transcribing data. However, the laboratory has not been correctly reporting Total Nitrogen. The lab has been reporting Total Kjeldahl Nitrogen (TKN) as Total Nitrogen. Total Nitrogen is calculated as the sum of TKN and Nitrate+Nitrite. 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. Report prepared by: Nick Jones Date: July 8, 2014 Report reviewed by: Tonja Springer Date: July 14, 2014