HomeMy WebLinkAbout#5659_0429_TS_2015_
INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #: 5659
Laboratory Name: Campbell Soup Supply Company, LLC
Inspection Type: Field Maintenance
Inspector Name(s): Tonja Springer
Inspection Date: April 29, 2015
Date Report Completed: June 3, 2015
Date Forwarded to Reviewer: June 3, 2015
Reviewed by: Todd Crawford
Date Review Completed: June 3, 2015
Cover Letter to use: Insp. Initial Insp. Reg.
Insp. No Finding Insp. CP
Corrected Insp. Reg. Delay
Unit Supervisor/Chemist III: Dana Satterwhite
Date Received: June 3, 2015
Date Forwarded to Linda: June 9, 2015
Date Mailed: June 9, 2015
_____________________________________________________________________
On-Site Inspection Report
LABORATORY NAME: Campbell Soup Supply Company, LLC
ADDRESS: 2120 Hwy. 71 North
Maxton, NC 28364
WATER QUALITY PERMIT # WQ0003626 (SI)
NC GENERAL PERMIT# NCG500205, NCG060029
CERTIFICATE #: 5659
DATE OF INSPECTION: April 29, 2015
TYPE OF INSPECTION: Field Initial
AUDITOR(S): Tonja Springer and Beth Swanson
LOCAL PERSON(S) CONTACTED: Jamie Collins and Jeff Scott
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 first inspection of the facility since being issued certification on October 20, 2014.
The facility has all the equipment necessary to perform the analyses.
Proficiency Testing Proficiency Testing (PT) samples for the 2015 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, 2015.
Contracted analyses are performed by Environmental Science Corporation dba: ESC Lab Sciences
(Certification #375) and Environmental Hydrogeological Consultants, Inc. (Certification #5538).
Current quality assurance policies for Field Laboratories, an example benchsheet 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:
Documentation
A. Finding: Several instances of writing over a number as a means of error correction were
observed. Error corrections were not initialed or dated.
Page 2
#5659 Campbell Soup Supply Company, LLC
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.
B. Finding: The laboratory needs to increase the documentation of purchased reagents.
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. 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.
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. Ref: The Quality Assurance Policies for Field Laboratories. Please submit a copy
of an updated completed benchsheet [or a log form may be used] that includes the
required traceability information with the response to this report.
Comment: Traceability information was not documented or referenced on all the benchsheets.
Benchsheets only had the Vendor, which was typed in on the benchsheets. Only one benchsheet
had all the required information. As a reminder, whenever changes occur (such as new reagents
are purchased, a new TRC curve is verified, etc.) information will need to be updated on the
original benchsheet template in the computer and an updated benchsheet printed.
Recommendation: It is recommended that the lab type in all the required information on the
benchsheet template.
pH – Standard Methods, 4500 H+ B-2000
Comment: The pH meter was not being calibrated properly. The analyst thought he was calibrating the
meter but he was only reading each buffer as a sample and not actually performing a calibration. This
was the being done from September, 2014 until February, 2015. The NC WW/GW LC Approved
Procedure for the Analysis of pH states: Instruments are to be calibrated according to the manufacturer’s
calibration procedure prior to analysis of samples each day compliance monitoring is performed. Use a
pH meter accurate and reproducible to 0.1 pH unit (as demonstrated daily by acceptable performance of
a check standard buffer) with a range of 0 to 14 and equipped with temperature-compensation
adjustment. The meter must be calibrated with at least two buffers. In addition to the calibration buffers,
the meter calibration must be verified with a third standard buffer solution. The calibration and check
standard buffers must bracket the range of the samples being analyzed. The laboratory discovered that
they were not calibrating the meter properly and corrected it on their own prior to the inspection.
Demonstration of acceptable corrective action (i.e., laboratory records reviewed during the audit) showed
that calibrations were being performed properly since March, 2015. No further response is necessary
for this finding.
Recommendation: Buffers are not poured fresh each analysis day. This is recommended because
buffer solutions may deteriorate as a result of mold growth or contamination.
Comment: The laboratory is documenting time sampled and time analyzed. Since samples are analyzed
immediately at the sampling site, one time may be documented for collection and analysis with the
notation that samples are measured in situ or immediately at the sample site.
Page 3
#5659 Campbell Soup Supply Company, LLC
C. Finding: The meter calibration is done each analysis day but neither the calibration nor the
calibration time is documented.
Requirement: The following must be documented in indelible ink whenever sample analysis is
performed: Meter calibration and meter calibration time(s). Ref: The NC WW/GW LC Approved
Procedure for the Analysis of pH. Please send 1 month of updated benchsheets that include
both meter calibrations and sample results with the response to this report.
Comment: Samples are analyzed 5 days a week. The benchsheet had enough spaces to
document the 5 sample analyses but only enough space to document 2 calibrations. Therefore,
calibrations were only documented on Mondays and Fridays.
Comment: An example benchsheet was designed for the laboratory that has an adequate
number of spaces for documenting 5 days of calibration and calibration times.
D. Finding: The laboratory benchsheet was lacking pertinent data: Instrument identification.
Requirement: The following must be documented in indelible ink whenever sample analysis is
performed: Instrument identification. Ref: The NC W W/GW LC Approved Procedure for the
Analysis of pH. Please submit a copy of an updated benchsheet showing the instrument
identification with the response to this report.
E. 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-2000, (6).
Proficiency Testing
F. Finding: The laboratory is not documenting PT sample analyses in the same manner as
environmental samples.
Requirement: All PT sample analyses must be recorded in the daily analysis records as for any
environmental sample. This serves as the permanent laboratory record. Ref: Proficiency
Testing Requirements, February 20, 2012, Revision 1.2.
Comment: PT samples are not being documented on the benchsheets. Results were only
documented on the vendor reporting form then submitted to the vendor by mail. The forms are
retained for 5 years.
G. Finding: The laboratory is not analyzing Proficiency Testing (PT) samples in the same manner
as environmental samples.
Requirement: All PT samples are to be analyzed and the results reported in a manner
consistent with the routine analysis and reporting requirements of compliance samples and any
other samples analyzed according to the requirements of 15A NCAC 2H .0800. Ref: Proficiency
Testing Requirements, February 20, 2012, Revision 1.2.
Page 4
#5659 Campbell Soup Supply Company, LLC
Comment: The laboratory’s common practice was to analyze a known standard along with the PT
sample as additional quality control. Since this is not performed with all environmental samples, it
is considered additional quality control. However, known samples are recommended when
analyzing remedial PT samples as part of the troubleshooting and corrective action process.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks, etc.)
and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to th e North Carolina
Division of Water Resources. Data were reviewed for WQ0003626 for January and March, 2015. No
transcription errors were detected. The facility appears to be doing a good job at accurately transcribing
data.
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 and include an implementation date for each
corrective action.
Report prepared by: Tonja Springer Date: June 3, 2015
Report reviewed by: Todd Crawford Date: June 3, 2015