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Home My WebLink About#5165-final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5165 Laboratory Name: E. I. DuPont Inspection Type: Field Maintenance Inspector Name(s): Todd Crawford Inspection Date: June 10, 2010 Date Report Completed: June 15, 2010 Date Forwarded to Reviewer: June 15, 2010 Reviewed by: Jeff Adams Date Review Completed: June 15, 2010 Cover Letter to use: Insp. Initial _ Insp. Reg. X Insp. No Finding Insp. CP Unit Supervisor: Dana Satterwhite Date Received: June 16, 2010 Date Forwarded to Alberta: June 17, 2010 Date Mailed: June 17, 2010 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: E. I. DuPont NPDES PERMIT #: NC0003760 ADDRESS: P.O. Box 800 Kinston, NC 28502-0800 CERTIFICATE #: 5165 DATE OF INSPECTION: June 10, 2010 TYPE OF INSPECTION: Field Maintenance AUDITOR(S): Todd Crawford LOCAL PERSON(S) CONTACTED: James Proctor and Jeff White 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 facility has all the equipment necessary to perform the analyses. Technical Assistance documents for all certified parameters were provided at the time of the inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Quality Control Comment: The facility is using an auto-pipettor for the reagent delivery and standard preparation associated with Total Residual Chlorine (TRC) analysis. The pipettor was purchased in March, 2010 and came with a statement of accuracy. This statement is good for 1 year. The North Carolina Wastewater/Groundwater Laboratory Certification document, Quality Assurance Policies for Field Laboratories, states: Mechanical volumetric liquid-dispensing devices (e.g., fixed and adjustable auto- pipettors, bottle-top dispensers, etc.) must be calibrated at least every twelve months. Each liquid- dispensing device must meet the manufacturer’s statement of accuracy. For variable volume devices used at more than one setting, check the accuracy at the maximum, middle and minimum values. Testing at more than three volumes is optional. When a device capable of variable settings is dedicated to dispense a single specific volume, calibration is required at that setting only. The calibration policy, instructions and spreadsheet for associated calculations have been provided to the facility. Documentation Comment: The laboratory is documenting the received and opened dates on the bottles of purchased standards and reagents but does not have a system of traceability beyond the life of the bottle. The North Carolina Wastewater/Groundwater Laboratory Certification document, Quality Assurance Policies for Field Laboratories, 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. A system (e.g., traceable identifiers) must be in place that links Page 2 #5165 E.I. DuPont 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 chemicals, reagents, standards and consumables used for a period of five years. Consumable materials such as pH buffers and lots of pre-made standards are included in this requirement. A form for documenting traceability of purchased standards and reagents as well as form documenting traceability of prepared standards and reagents was provided to the facility at the time of the inspection. No further response is necessary for this finding. Comment: The pH benchsheet incorrectly referenced EPA Method 150.1. The benchsheet was corrected to reference Standard Method, 4500 H+ B while the auditor was still onsite. No further response is necessary for this finding. Comment: Several instances of improper error corrections were observed. The North Carolina Wastewater/ Groundwater Laboratory Certification document, Quality Assurance Policies for Field Laboratories, 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-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. This policy was discussed with all analysts at the time of the inspection. No further response is necessary for this finding. Residual Chlorine – Standard Methods, 20th Edition, 4500 Cl G Comment: The HACH meter internal calibration curve has been verified across a range of 10 -50 µg/L. While this range encompasses the facility’s discharge limit and the expected range of sample concentrations, it most likely will not encompass the concentration of a blind Performance Evaluation (PE) sample. Please be aware that all samples and PE sample concentrations must fall within the verified range of the meter. While samples may be diluted to fall within this range; dilution is a source of additional error and is not recommended. The preferred solution is to extend the upper limit of the curve verification to include both environmental samples and PE samples. Recommendation: When documenting sample results that are below the lowest verified calibration standard on the laboratory benchsheet, write down the number exactly as it appears on the meter display. When transferring that result to the Discharge Monitoring Report (DMR), write the result as “<” the lowest calibration verification standard. IV. PAPER TRAIL INVESTIGATION: Washington Regional Office inspector, Robert Bullock, conducted a paper trail investigation on February 17, 2010. The auditor felt that an additional paper trail investigation at this time was not warranted. V. CONCLUSIONS: 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: Todd Crawford Date: June 15, 2010 Report reviewed by: Jeff Adams Date: June 15, 2010