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Home My WebLink About#5139_11_2014_final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5139 Laboratory Name: Bensinger & Garrison Environmental, Inc. Inspection Type: Field Commercial Maintenance Inspector Name(s): Tonja Springer Inspection Date: 11/25/2014 Date Report Completed: December 12, 2014 Date Forwarded to Reviewer: December 12, 2014 Reviewed by: Jason Smith Date Review Completed: 12/12/14 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: 12/15/2014 Date Forwarded to Linda: 12/15/2014 Date Mailed: 12/16/2014 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Bensinger & Garrison Environmental, Inc. ADDRESS: P.O Box 14609 Research Triangle Park, NC 27709 NPDES PERMIT # NC0080519 CERTIFICATE #: 5139 DATE OF INSPECTION: November 25, 2014 TYPE OF INSPECTION: Field Commercial Maintenance AUDITOR(S): Tonja Springer LOCAL PERSON(S) CONTACTED: Steve Gerrald and Wes Brummer 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: Benchsheets are well designed, easy to follow and concise. Records are well organized and easy to retrieve. 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: Proficiency Testing Comment: The laboratory was not analyzing Proficiency Testing (PT) samples in the same manner as environmental samples. Samples were analyzed multiple times and the average was reported. The Proficiency Testing Requirements, February 20, 2012, Revision 1.2 document states: 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. This requirement is a new policy that has been implemented by our program since the last inspection. Notification of acceptable corrective action (i.e., a statement that Proficiency Testing samples will be analyzed “as a sample” and submitted results will not be averaged) was received by email on December 3 2014. No further response is necessary for this finding. Documentation Comment: The laboratory benchsheets for Temperature, pH and Conductivity were lacking pertinent data: Instrument identification. The NC WW/GW LC Approved Procedure for the Analysis of Temperature, NC WW/GW LC Approved Procedure for the Analysis of pH, and NC WW/GW LC Page 2 #5139 Bensinger & Garrison Environmental, Inc. Approved Procedure for the Analysis of Conductivity documents state: The following must be documented in indelible ink whenever sample analysis is performed: Instrument Identification. Demonstration of acceptable corrective action (i.e., an example benchsheet with a space provided for instrument identification) was received by email on December 3, 2014. No further response is necessary for this finding. Comment: The meter calibration time was not documented on the Conductivity benchsheet and was not documented clearly on the pH benchsheet. The NC WW/GW LC Approved Procedure for the Analysis of Conductivity and NC WW/GW LC Approved Procedure for the Analysis of pH documents state: The following must be documented in indelible ink whenever sample analysis is performed: Meter calibration time. Demonstration of acceptable corrective action (i.e., an example benchsheet with a space provided to document the Conductivity and pH meter calibration time) was received by email on December 3, 2014. No further response is necessary for this finding. Comment: The temperature correction (this was -0.6°C at the time of the inspection) for the combined Conductivity/pH/Temperature meter has not been posted nor has the correction been applied to the reported temperature reading. The NC WW/GW LC Approved Procedure for the Analysis of Temperature document states: The following must be documented in indelible ink whenever sample analysis is performed. Document sample temperature measurements with any applicable temperature corrections applied. The temperature correction (even if it is zero) must be posted on the meter as well as in hard copy format (to be retained for five years). Notification of acceptable corrective action (i.e., a statement that Temperature results will be reported to the nearest whole degree C; instead of tenth degree C, after applying any correction and a label was added with temperature correction value to the combined pH/Conductivity/Temperature meter) was received by email on December 3, 2014. No further response is necessary for this finding. Comment: The laboratory needs to increase the documentation of purchased reagents. Only the Lot Number and Vendor information was being documented. The Quality Assurance Policies for Field Laboratories document 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 standard/reagent preparation information to analytical batches in which the solutions are used. Consumable materials such as pH buffers and lots of pre-made standards are included in this requirement. Demonstration of acceptable corrective action (i.e., a traceability log with all the required documentation except Date Received) was received by email on December 3, 2014. Notification of acceptable corrective action (i.e., a statement that Date Received was added to the traceability log) was received by email on December 10, 2014. No further response is necessary for this finding. pH – Standard Methods, 4500 H+ B-2000 Comment: Values were reported that exceed the method specified accuracy of 0.1 units. Standard Methods, 4500 H+ B-2000 (6) states in part: 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. Notification of acceptable corrective action (i.e., a statement that pH results will be reported to the nearest tenth Standard Units (S.U). instead of hundredth S.U.) was received by email on December 3, 2014. No further response is necessary for this finding. Comment: A check buffer (7.0 S.U.) was not being analyzed after the calibration. The NC WW/GW LC Approved Procedure for the Analysis of pH document states: 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 check standard buffer Page 3 #5139 Bensinger & Garrison Environmental, Inc. must read within ±0.1 S.U. to be acceptable. If the meter verification does not read within ±0.1 S.U., the meter must be recalibrated before any samples are analyzed. Notification of acceptable corrective action (i.e., a statement that instrument calibration will be checked against intermediate range standard solutions after calibration and before sampling and recorded on the bench sheet) was received by email on December 3, 2014. No further response is necessary for this finding. Comment: The benchsheets for pH did not contain all of the necessary labeling information. Units of measure were being documented for the calibration but not for the results column. The North Carolina Administrative Code, 15A NCAC 2H .0805 (g) (1) states: The field benchsheets must provide a space for the signature of the analyst, and proper units of measure for all analyses. Notification of acceptable corrective action (i.e., a statement that units had been added to the results column of the benchsheet) was received by email on December 10, 2014. No further response is necessary for this finding. Conductivity – EPA Method 120.1, Rev. 1982 Comment: A calibration check standard was not being analyzed immediately after the calibration and prior to environmental sample analysis. The NC WW/GW LC Approved Procedure for the Analysis of Conductivity document states: Analyze and document a calibration verification check standard prior to environmental sample analysis. It is recommended that this standard value bracket (may be higher or lower than the calibration standard, as applicable) the expected range of sample values measured. The value obtained for the calibration verification check standard must read within 10% of the true value of the calibration verification check standard. If the obtained value is outside of the ±10% range, corrective action must be taken. Notification of acceptable corrective action (i.e., a statement that instrument calibration will be checked against intermediate range standard solutions after calibration and before sample analysis and recorded on the bench sheet) was received by email on December 3, 2014. No further response is necessary for this finding. Comment: The Automatic Temperature Compensator (ATC) has not been verified annually (i.e., 12 months). The NC WW/GW LC Approved Procedure for the Analysis of Conductivity document states: The ATC must be verified annually (i.e., 12 months) at two temperatures by analyzing a standard or sample at 25°C (the temperature that conductivity values are compensated to) and a temperature(s) that brackets the temperature ranges of the environmental samples routinely analyzed. This may require the analysis of a third temperature reading that is > 25°C. The manner in which the ATC is verified may depend upon the meter’s capabilities and the manufacturer’s instructions. As the temperature increases or decreases, the value of the conductivity standard or sample must be within 10% of the true value of the standard or 10% of the value of the sample at 25°C. If not, corrective action must be taken. Demonstration of acceptable corrective action (i.e., a copy of the ATC verification) was received by email on December 3, 2014. Notification of acceptable corrective action (i.e., that the following statement: In order to prevent future lapses in ATC verification I have added the annual ATC Check date to our equipment maintenance log located at the front of our Field Lab records. I have also created a checklist of items to be completed with our next proficiency test, which includes the annual ATC check) was received by email on December 15, 2014. No further response is necessary for this finding. 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 the North Carolina Division of Water Resources. Data were reviewed for July and October, 2014. No transcription errors were detected. It appears the facility is doing a good job of accurately transcribing data. Page 4 #5139 Bensinger & Garrison Environmental, Inc. 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: Tonja Springer Date: December 12, 2014 Report reviewed by: Jason Smith Date: December 12, 2014