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INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #: 5378
Laboratory Name: DAK Americas Cedar Creek
Inspection Type: Field Maintenance
Inspector Name(s): Tonja Springer
Inspection Date: February 18, 2014
Date Report Completed: March 14, 2014
Date Forwarded to Reviewer: March 14, 2014
Reviewed by: Nick Jones
Date Review Completed: March 20, 2014
Cover Letter to use: Insp. Initial Insp. Reg.
Insp. No Finding Insp. CP
Corrected
Unit Supervisor/Chemist III: Dana Satterwhite
Date Received: 3/25/2014
Date Forwarded to Linda: 4/24/2014
Date Mailed: 4/24/2014
_____________________________________________________________________
Tonja – Please send a copy of this report to Belinda Henson in FRO.
On-Site Inspection Report
LABORATORY NAME: DAK Americas Cedar Creek
WATER QUALITY PERMIT # : NC0003719
ADDRESS: 3216 Cedar Creek Rd.
Fayetteville, NC 28312
CERTIFICATE #: 5378
DATE OF INSPECTION: February 18, 2014
TYPE OF INSPECTION: Field Maintenance
AUDITOR(S): Tonja Springer
LOCAL PERSON(S) CONTACTED: Donald Allbright
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:
The laboratory was clean and well organized. The facility has all the equipment necessary to perform the
analyses.
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.
Contracted analyses are performed by TBL Environmental Laboratory, Inc. (Certification #37) and
Environment 1, Inc. (Certification #10).
The requirement associated with Finding C has been implemented by our program since the last
inspection.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Total Residual Chlorine – Standard Methods, 4500 Cl G-2000
Dissolved Oxygen – Standard Methods, 4500 O G-2001
Temperature – Standard Methods, 2550 B-2000
pH – Standard Methods, 4500 H+B-2000
Recommendation: The laboratory’s data defensibility would be improved with the addition of an
instrument maintenance log. This can be as simple as a description in a comment box on a
benchsheet. One example of instrument maintenance is replacing a bulb on the Total Residual
Chlorine meter.
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Comment: Instrument identification and facility name for the meters used for Temperature, pH,
Dissolved Oxygen and Total Residual Chlorine were not documented on the benchsheet. The NC
WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine, the NC WW/GW LC
Approved Procedure for the Analysis of Dissolved Oxygen, the NC WW/GW LC Approved Procedure
for the Analysis of Temperature, and the 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: Instrument identification and facility name. This requirement is a new policy that has been
implemented by our program since the last inspection. Demonstration of acceptable corrective action
(i.e., an updated benchsheet which included the instrument ID and facility name) was received by email
on 2/25/2014. No further response is necessary for this finding.
Comment: Several instances of writing over a number as a means of error correction were observed.
The Quality Assurance Policies for Field Laboratories document 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. Demonstration of
acceptable corrective action (i.e., an updated benchsheet which included error correction policy) was
received by email on 2/25/2014. No further response is necessary for this finding.
Total Residual Chlorine – Standard Methods, 4500 Cl G-2000
pH – Standard Methods, 4500 H+B-2000
Comment: The laboratory needs to increase the documentation of purchased materials and reagents,
as well as documentation of standards and reagents prepared in the laboratory. The 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 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. This
requirement is a new policy that has been implemented by our program since the last inspection.
Demonstration of acceptable corrective action (i.e., an updated benchsheet which included traceability
for the pH buffers and Total Residual Chlorine reagents, standards and gel standards, and a statement
that the preparation of the 2014 annual Total Residual Chlorine verification curve standards will be
documented and the documentation kept for 5 years) was received by email on 2/25/2014. No further
response is necessary for this finding.
Proficiency Testing (PT)
Comment: The laboratory is not designating the correct method code(s) for proficiency testing sample
results. The Proficiency Testing Requirements, February 20, 2012, Revision 1.2 document states: To
ensure that you are reporting the correct method, review your certificate attachment (i.e., certified
parameter list). The method must include the entire method reference as is written on your certificate
attachment (i.e., certified parameter list). This is a new policy that has been implemented by our
program since the last inspection. Notification of acceptable corrective action (i.e., an email statement
that for the entire method reference, as it appears on the certificate att achment, will be documented
beginning with the 2014 PT results) was received by email on 2/25/2014. No further response is
necessary for this finding.
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Comment: Designating the correct method code(s) will ensure you receive proper credit for the
parameter method technologies on your current certificate attachment. When a PT provider utilizes a
web-based submittal system, where the laboratory selects the analytical method from a pull-down list, it
may be necessary to edit the choices given. Technical difficulties should be addressed with the PT
provider.
Comment: The laboratory is not documenting Proficiency Testing (PT) sample analyses in the same
manner as environmental samples. The Proficiency Testing Requirements, February 20, 2012,
Revision 1.2 document states: All PT sample analyses must be recorded in the daily analysis records
as for any environmental sample. This serves as the permanent laboratory record. 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 is a new policy that has been implemented by our program since the last
inspection. Notification of acceptable corrective action (i.e., an email statement that the lab will
document PT sample analysis in the same manner as environmental samples beginning with the 2014
PT samples) was received by email on 2/25/2014. No further response is necessary for this
finding.
Comment: The preparation of Total Residual Chlorine (TRC) Proficiency Testing (PT) samples is not
documented. The Proficiency Testing Requirements, February 20, 2012, Revision 1.2 document
states: PT samples received as ampules must be diluted according to the PT provider’s instructions.
The preparation of PT samples must be documented in a traceable log or other traceable format. The
diluted PT sample becomes a routine environmental sample and is added to a routine sample batch for
analysis. This is a new policy that has been implemented by our program since the last inspection.
Notification of acceptable corrective action (i.e., an email statement that for the preparation of PT
samples will be documented in a traceable log beginning with the 2014 PT samples) was received by
email on 2/25/2014. No further response is necessary for this finding.
Total Residual Chlorine – Standard Methods, 4500 Cl G-2000
Comment: The laboratory has been using the liquid reagents. At the time of the inspection, laboratory
personnel indicated they will be switching to DPD powder reagents. This would be more economical in
terms of both time and costs and will eliminate the need for calibrated pipettors. Use of the flow-thru
cell could also be discontinued.
Comment: The auto-pipettors have not been calibrated annually as required. The Quality Assurance
Policies for Field Laboratories document states: Mechanical volumetric liquid-dispensing devices (e.g.,
fixed and adjustable auto-pipettors, bottle-top dispensers, etc.), used for critical measurements, must
be calibrated at least every twelve months and documented. 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. This is a new policy that has been implemented by
our program since the last inspection. Notification of acceptable corrective action (i.e., an email
statement that they will be switching to DPD powder and will consequently no longer be using the auto
pipettors, effective March 5, 2014) was received by email on 2/25/2014. No further response is
necessary for this finding.
Comment: Concentrations less than the established reporting limit of 20 µg/L are being reported on
the Discharge Monitoring Report (DMR). The NC WW/GW LC Approved Procedure for Analysis of Total
Residual Chlorine document states: For analytical procedures requiring analysis of a series of standards,
the concentrations of those standards must bracket the concentration of the samples analyzed. One of
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the standards must have a concentration equal to the laboratory’s lower reporting concentration for the
parameter involved. Demonstration of acceptable corrective action (i.e., a benchsheet with a statement
on the bottom to report results as <20 µg/L since the lowest calibration verification standard is 20 µg/L)
was received by email on 2/25/2014. No further response is necessary for this finding.
A. Finding: The gel standard used for the daily check standard was often outside the
acceptance criterion and no corrective actions were taken.
Requirement: The value obtained for the check standard must read within 10% of the true
value of the check standard. If the obtained value is outside the +10% range, corrective action
must be taken. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual
Chlorine.
Comment: The gel standard reading outside the acceptance criterion indicates a problem with
either the gel standard or the meter. It is our belief that the consistent unacceptable reading of
the gel standard indicates the problem is most likely with the meter. Troubleshooting and
corrective action measures must be taken. Troubleshooting could consist of analyzing a known
value sample from a PT provider to confirm the accuracy of the meter. If it is demonstrated that
there is a problem with the meter, it must be serviced and repaired in accordance with North
Carolina Administrative Code, 15A NCAC 2H .0805 (g) (4).
Comment: Since the inspection, the laboratory has purchased a new gel standard and a true
value has been assigned. The assigned gel standard value is 190 µg/L. This new gel standard
has been reading within the acceptance criterion. A known value quality control standard has
also been ordered from a PT provider to confirm the accuracy of the meter. Please submit a
copy of the raw data for the known standard analysis (i.e., benchsheet documentation) and the
results obtained with the true value assigned by the manufacturer upon completion.
Comment: The gel standards must be verified initially and every 12 months thereafter, with the
standard curve. When this is done, these standards may be used after the manufacturer’s
expiration date. It is only necessary to verify the gel or sealed liquid standard which falls within
the concentration range of the curve used to measure sample concentrations. The assigned
values will be used for the next twelve months, or until a new curve verification is performed.
The gel/liquid standard verification must be performed for each instrument on which they are to
be used. Documentation must link the gel standard identification to the meter with which the
assigned value was determined.
B. Finding: Data that does not meet all quality control requirements is not qualified on the
Discharge Monitoring Report (DMR).
Requirement: When quality control (QC) failures occur, the laboratory must attempt to
determine the source of the problem and must apply corrective action. Part of the corrective
action is notification to the end user. If data qualifiers are used to qualify samples not meeting
QC requirements, the data may not be useable for the intended purposes. It is the responsibility
of the laboratory to provide the client or end-user of the data with sufficient information to
determine the usability of the qualified data. Where applicable, a notation must be made on the
Discharge Monitoring Report (DMR) form, in the comment section or on a separate sheet
attached to the DMR form, when any required sample quality control does not meet specified
criteria and another sample cannot be obtained. Ref: Quality Assurance Policies for Field
Laboratories.
Comment: The gel standard used for the daily check standard was consistently outside the
acceptance criterion on the dates listed in the table below and the data was not qualified on the
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Discharge Monitoring Reports. It appears, from the values obtained for the check standard, that
the Total Residual Chlorine results reported for environmental samples on these dates may be
biased low (if it is determined during the troubleshooting process that the gel standard value was
accurate).
Date Assigned value of
the Gel Standard
Acceptable Range Value obtained
August 1, 2013 233 µg/L 210 µg/L – 256 µg/L 197 µg/L
August 10, 2013 233 µg/L 210 µg/L – 256 µg/L 196 µg/L
August 16, 2013 233 µg/L 210 µg/L – 256 µg/L 194 µg/L
August 20, 2013 233 µg/L 210 µg/L – 256 µg/L 202 µg/L
September 9, 2013 233 µg/L 210 µg/L – 256 µg/L 203 µg/L
September 12, 2013 233 µg/L 210 µg/L – 256 µg/L 202 µg/L
September 19, 2013 233 µg/L 210 µg/L – 256 µg/L 197 µg/L
September 25, 2013 233 µg/L 210 µg/L – 256 µg/L 199 µg/L
October 5, 2013 233 µg/L 210 µg/L – 256 µg/L 198 µg/L
October 10, 2013 233 µg/L 210 µg/L – 256 µg/L 201 µg/L
October 17, 2013 233 µg/L 210 µg/L – 256 µg/L 203 µg/L
October 26, 2013 233 µg/L 210 µg/L – 256 µg/L 204 µg/L
November 28, 2013 233 µg/L 210 µg/L – 256 µg/L 212 µg/L
Recommendation: It is recommended that you contact the Fayetteville Regional Office for
guidance as to whether amended Discharge Monitoring Reports will be required, if it is found,
during the troubleshooting process, that the meter was not operating properly. A copy of this
report will be made available to the Regional Office.
C. Finding: A reagent blank was not analyzed when the annual verification curve was analyzed on
5/3/2013.
Requirement: A reagent blank (sometimes also referred to as a method blank) is only required
when laboratory water is used to make quality control and/or calibration standards. If you are
using a sealed standard (e.g., gel) for your daily check standard, a reagent blank would only be
analyzed when preparing the annual 5-point calibration curve or 5 annual calibration curve
verification standards. A reagent blank is made from the same laboratory water source used to
make quality control and/or calibration standards with DPD. The concentration of reagent
blanks must not exceed 50% of the reporting limit (i.e., the lowest calibration or calibration
verification standard concentration), unless otherwise specified by the reference method, or
corrective action must be taken. Ref: NC WW/GW LC Approved Procedure for the Analysis of
Total Residual Chlorine. Please send a copy of the annual verification curve, including
documentation of the reagent blank analysis, upon completion.
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 would be reported to 0.1 units) was received by e-mail on 2/25/2014. No
further response is necessary for this finding.
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Temperature – Standard Methods, 2550 B-2000
Comment: The temperature correction is not posted the benchsheet or on the Dissolved Oxygen
meter used to obtain reported temperature values. The NC WW/GW LC Approved Procedure for
Temperature document states: The following must be documented in indelible ink whenever sample
analysis is performed: 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 5 years). Demonstration of acceptable corrective action
(i.e., an updated benchsheet which included the temperature correction and a statement that the
correction has been posted on the meter) was received by email on 2/25/2014. No further response
is necessary for this finding.
Comment: The temperature correction is not applied to the compliance sample results. The NC
WW/GW LC Approved Procedure for the Analysis of Temperature document states: All thermometers
and temperature measuring devices must be checked every 12 months against a National Institute of
Standards and Technology (NIST) traceable thermometer. The process must be documented and
proper corrections made to all compliance data. To check a thermometer or the temperature sensor of
a meter, read the temperature of the thermometer/meter against a NIST traceable thermometer and
record the two temperatures. The verification must be performed in the approximate range of the
sample temperatures measured. The thermometer/meter readings must be less than or equal to 1ºC
from the NIST traceable thermometer reading. The documentation must include the serial number of
the NIST traceable thermometer that was used in the comparison. Demonstration of acceptable
corrective action (i.e., an updated benchsheet which included the statement that the temperature
correction would be applied to all reported sample measurements) was received by email on
2/25/2014. No further response is necessary for this finding.
Recommendation: It is recommended that you contact the Fayetteville Regional Office for guidance
as to whether amended Discharge Monitoring Reports will be required. A copy of this report will be
made available to the Regional Office.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing laboratory benchsheets and contract lab reports to Discharge
Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Resources. Data were
reviewed for July and September, 2013. No transcription errors were detected. The facility appears to
be doing a good job of accurately transcribing data.
V. CONCLUSIONS:
Correcting the above-cited findings and implementing the recommendations 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: Tonja Springer Date: March 14, 2014
Report reviewed by: Nick Jones Date: March 20, 2014