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HomeMy WebLinkAbout#50 - 04 -2012 - FINALINSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 50 Laboratory Name: Water Tech Labs, Inc. Inspection Type: Commercial Maintenance Inspector Name(s): Gary Francies, Chet Whiting, Jason Smith, Nick Jones Inspection Date: April 2, 2012 Date Report Completed: May 1, 2012 Date Forwarded to Reviewer: May 1, 2012 Reviewed by: Chet Whiting Date Review Completed: May 1, 2012 Cover Letter to use: _ Insp. Initial _ Insp. Reg. _ Insp. No Finding _ Insp. CP X Corrected Unit Supervisor: Gary Francies Date Received: 5/1/2012 Date Forwarded to Linda: 5/15/2012 Date Mailed: 741 , ffe NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Governor 50 Mr. Tony Gragg Water Tech Labs, Inc P.O. Box 1056 5 Pinewood Plaza Granite Falls, NC 28630 Charles Wakild, P. E. Director May 16, 2012 Dee Freeman Secretary SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Gragg: Enclosed is a report for the inspection performed on April 2, 2012 by Jason Smith. Since the finding(s) cited during the inspection were all corrected prior to the completion of the enclosed report, a response is not required. The staff is commended for taking the initiative in correcting the findings in such a timely manner. 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 electronic mail, or if you have questions or need additional information please contact me at 828-296-4677. Sincerely, Gary 'Francies Certification Unit Supervisor Laboratory Section CC: Jason Smith Master File DENR DWO Laboratory Section NC Wastewater/Groundwater Laboratory Certification Branch 1623 Mail Service Center, Raleigh, North Carolina 27699-1623 Location: 4405 Reedy Creek Road. Raleigh, North Carolina 27607-6445 Phone: 919-733-3908 \ FAX: 919-733-6241 Internet: www.dwglab.org One N6 ihCarolina ;Vatu-milb, An Equal Opportunity \ Affirmative Action Employer On -Site Inspection Report LABORATORY NAME: Water Tech Labs, Inc. ADDRESS: P.O. Box 1056 5 Pinewood Plaza Granite Falls, NC 28630 CERTIFICATE #: DATE OF INSPECTION: TYPE OF INSPECTION: AUDITOR(S): LOCAL PERSON(S) CONTACTED: INTRODUCTION: 50 April 2, 2012 Commercial Maintenance Jason Smith, Gary Francies, Chet Whiting, and Nick Jones Tony Gragg, Kathy Gragg, Joe Gragg, and Jonathon Gragg This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for the analysis of environmental samples. IL GENERAL COMMENTS: The facility is neat and well organized and has all Benchsheets are well designed, easy to follow computers, are well organized and easy to retrieve. the equipment necessary to perform the analyses. and concise. Records, which are maintained on The laboratory is reminded that any time changes are made to laboratory operations; the laboratory must update the Quality Assurance (QA)/Standard Operating Procedures (SOP) document(s). Any changes made in response to the Findings, Recommendations or Comments listed in this report must be incorporated to insure the method is being performed as stated, references to methods are accurate, and the QA and/or SOP document(s) is in agreement with approved practice and regulatory requirements. In some instances, the laboratory may need to create a SOP to document how new functions or policy will be implemented. III. FINDINGS REQUIREMENTS COMMENTS AND RECOMMENDATIONS: Documentation Comment: Some instances of overwriting were noted and error corrections were not dated. North Carolina Wastewater/Groundwater Laboratory Certification Policy 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 requirement is a new policy that has been implemented by our program since the last inspection. Notification of acceptable corrective action (i.e., all personnel have been notified of this policy) was received by email on April 13, 2012. No further response is necessary for this finding. Page 2 #50 Water Tech Labs, Inc. Comment: Proficiency Testing (PT) samples were not analyzed and documented the same as environmental samples. Orthophospate samples were documented on the benchsheet with Total Phosphorus, PT sample preparation was not documented, and PT samples were not logged in the same as environmental samples. North Carolina Wastewater/Groundwater Laboratory Certification Policy states: The analysis of PT samples is designed to evaluate the entire process used to routinely report environmental analytical results; therefore, PT samples must be analyzed and the process documented in the same manner as environmental samples. This requirement is a new policy that has been implemented by our program since the last inspection. Notification of acceptable corrective action (i.e., all PT samples will be included in the receipt log and treated as typical samples from receipt to preparation and analysis) was received by email on April 13, 2012. No further response is necessary for this finding. Comment: Although it is not currently always easy to follow, the laboratory has a thorough system of traceability which is in the process of being updated and improved. Comment: The method edition was not consistently documented on benchsheets and Standard Operating Procedures (SOPs). Updated benchsheets and example SOP cover sheets including the correct references were submitted by email on April 13, 2012. General Laboratory Comment: Meters that are not being used to generate reportable temperature data are no longer required to have the temperature sensor checked against an NIST thermometer annually. This applies to this laboratory as well as other field laboratories that they assist with the NIST temperature checks. Alkalinity — Standard Methods, 201h Edition, 2320 B Comment: The laboratory does not analyze Alkalinity samples for wastewater, only for Drinking Water. The SOP includes subtracting the blank from sample results. The formula to calculate Alkalinity in Standard Methods, 20th Edition, 2320 B. (5) (a) is: Alkalinity, mg CaCO3/L = (A x N x 50,000) / mL sample Where: A = mL standard acid used and N = normality of standard acid A blank subtraction is not in the formula or the method. Notification of acceptable corrective action (i.e., the SOP and benchsheet have been updated to no longer perform a blank subtraction) was received by email on May 1, 2012. No further response is necessary for this finding. Hardness — Standard Methods, 20th Edition, 2340 C Comment: The laboratory was performing a blank subtraction on all sample results. Standard methods, 201h Edition, 2340 C. (3) (c) states: For ion -exchanger effluent or other softened water and for natural waters of low hardness (less than 5 mg/L), take a larger sample, 100 to 1000 mL, for titration and add proportionately larger amounts of buffer, inhibitor, and indicator. Add standard EDTA titrant slowly from a microburet and run a blank, using redistilled, distilled, or deionized water of the same volume as the sample, to which identical amounts of buffer, inhibitor, and indicator have been added. Subtract volume of EDTA used for blank from volume of EDTA used for sample. Notification of acceptable corrective action (i.e., a blank subtraction will now only be made on samples <5 mg/L) was received by email on April 13, 2012. No further response is necessary for this finding. Page 3 #50 Water Tech Labs, Inc. Settleable Residue — Standard Methods, 20th Edition, 2540 F Comment: The forty five minute stir time was not adequately documented. This is considered pertinent information. The North Carolina Administrative Code, 15A NCAC 2H .0805 (a) (7) (A) states: All analytical data pertinent to each certified analysis must be filed in an orderly manner so as to be readily available for inspection upon request. Demonstration of acceptable corrective action (i.e., an updated benchsheet including a space for the analyst to document the forty five minute stir time) was received by email on April 13, 2012. No further response is necessary for this finding. Total Suspended Solids — Standard Methods, 20th Edition, 2540 D Comment: Based on a recommendation during the inspection, the laboratory will now perform the annual drying study on the entire batch of samples rather than just one sample. This will help ensure that the annual drying study is performed on representative samples. Oil and Grease — EPA Method 1664 A Comment: The reporting limit was not calculated based on a 900 mL sample volume. EPA Method 1664 A. Section 12.1. states: Calculate as follows: HEM mg/L = the weight of extractable material / sample volume (Q. The manufacturer's sample container is designed to couple with the extraction system and holds a maximum volume of 900 mL. For sample containers that are full, the result must be calculated using this volume. Notification of acceptable corrective action (i.e., the reporting limit for full sample containers will now be based on 900 mL of sample) was received by email on April 13, 2012. No further response is necessary for this finding. Chemical Oxygen Demand — Standard Methods, 20th Edition, 5220 C Nitrate + Nitrite — Standard Methods, 20th Edition, 4500 NO3 E Total Phoshorus — Standard Methods, 20th Edition, 4500 P E Orthophosphate — Standard. Methods, 20th Edition, 4500 P E Ammonia Nitrogen — Standard Methods, 18th Edition, 4500 NH3 C Comment: The laboratory was not analyzing a blank after every ten samples and at the end of the sample batch. North Carolina Wastewater/Groundwater Laboratory Certification Policy based upon Standard Methods, 20th Edition, 1020 B. (10) (c), 3020 B. (2) (b), and 4020 B. (2) states: The calibration blank and calibration verification standard (mid -range) must be analyzed initially (i.e., prior to sample analysis), after every tenth sample and at the end of each sample group to check for carry over and calibration drift. If either fall outside established quality control acceptance criteria, corrective action must be taken (e.g., repeating sample determinations since the last acceptable calibration verification, repeating the initial calibration, etc.). This requirement is a new policy that has been implemented by our program since the last inspection. Notification of acceptable corrective action (i.e., this policy has been implemented for all colorimetric procedures) was received by email on April 13, 2012. No further response is necessary for this finding. Chemical Oxygen Demand — Standard Methods, 20th Edition, 5220 C Nitrate + Nitrite — Standard Methods, 20th Edition, 4500 NO3 E Orthophosphate — Standard, Methods, 20th Edition, 4500 P E Ammonia Nitrogen — Standard Methods, 181h Edition, 4500 NH3 C Comment: The volume of the matrix spike was >1% of the sample volume, but the dilution was not factored into the equation. North Carolina Wastewater/Groundwater Laboratory Certification Policy states: If the spike solution volume constitutes >1% of the total sample volume, the sample concentration or spike concentration must be adjusted by calculation. This requirement is a new policy that has been implemented by our program since the last inspection. Notification of acceptable corrective action (i.e., Page 4 #50 Water Tech Labs, Inc. the spike volumes have been adjusted to be :51 % of the sample volume) was received by email on April 13, 2012. No further response is necessary for this finding. Chemical Oxygen Demand — Standard Methods, 20th Edition, 5220 C Comment: The observed temperature of the digestion block was not documented. This is considered pertinent information. The North Carolina Administrative Code, 15A NCAC 2H .0805 (a) (7) (A) states: All analytical data pertinent to each certified analysis must be filed in an orderly manner so as to be readily available for inspection upon request. Demonstration of acceptable corrective action (i.e., an updated benchsheet including a space for the digestion block temperature to be recorded) was received by email on April 13, 2012. No further response is necessary for this finding. Nitrate + Nitrite — Standard Methods, 20th Edition, 4500 NO3 E Comment: Based on a recommendation during the inspection, the benchsheet has been updated to clarify the column efficiency check. Ammonia Nitrogen — Standard Methods, 18th Edition, 4500 NH3 C Comment: A new curve verification is not performed with each new lot number of nessler reagent. Standard Methods, 18th Edition, 4500 NH3 C. (4) (c) states: Redetermine complete calibration curve for each new batch of nessler reagent. Notification of acceptable corrective action (i.e., a new curve verification will be performed for each new lot number of nessler reagent) was received by email on April 13, 2012. No further response is necessary for this finding. IV. PAPER TRAIL INVESTIGATION: No paper trail performed. All findings noted during the inspection were adequately addressed prior to the completion of this report. The inspectors would like to thank the staff for its assistance during the inspection and data review process. No response is required. Report prepared by: Jason Smith Date: May 1, 2012 Report reviewed by: Chet Whiting Date: May 1, 2012