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Home My WebLink About#5005-final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5005 Laboratory Name: Lenoir County Public Schools Inspection Type: Field Maintenance Inspector Name(s): Todd Crawford Inspection Date: June 10, 2010 Date Report Completed: June 21, 2010 Date Forwarded to Reviewer: June 21, 2010 Reviewed by: Tonja Springer Date Review Completed: June 22, 2010 Cover Letter to use: Insp. Initial X Insp. Reg. ___Insp. No Finding Insp. CP Unit Supervisor: Dana Satterwhite Date Received: June 22, 1010 Date Forwarded to Alberta: June 22, 2010 Date Mailed: June 22, 2010 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Lenoir County Public Schools NPDES PERMIT #: NC0032565 ADDRESS: 1624 Hwy. 11/55 Kinston, NC 28504 CERTIFICATE #: 5005 DATE OF INSPECTION: June 10, 2010 TYPE OF INSPECTION: Field Maintenance AUDITOR(S): Todd Crawford LOCAL PERSON(S) CONTACTED: Wayne Taylor 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 A. Finding: The auto-pipettors have not been calibrated annually as required. Requirement: 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. Ref: Quality Assurance Policies for Field Laboratories. Documentation Comment: Performance Testing (PT) samples are being analyzed in the same manner as regulatory environmental samples but are not being documented in the same manner. The North Carolina Wastewater/Groundwater Laboratory Certification document, Quality Assurance Policies for Field Laboratories, 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 in the same manner as environmental samples. This would include the documentation. The sample location field on the benchsheet would be an appropriate place to document that the sample is a PT sample by listing the Page 2 #5005 Lenoir County Public Schools vendor and study number there. This requirement and procedure was discussed with the analyst at the time of the inspection. No further response is necessary for this finding. B. Finding: The laboratory needs to increase the documentation of purchased materials and reagents, as well as, documentation of standards and reagents prepared in the laboratory. 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. 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. Ref: Quality Assurance Policies for Field Laboratories. Residual Chlorine – Standard Methods, 18th 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 sample and PE sample concentrations. Recommendation: Extend the upper limit of the calibration verification curve to 300 µg/L. Recommendation: Replace the scratched flow-thru cell. C. Finding: The last chlorine calibration verification that was performed on June 22, 2009, did not pass quality control requirements. Requirement: Analyze a water blank to zero the instrument and then analyze a series of five standards. The curve verification must check 5 concentrations (not counting the blank) that bracket the range of the samples to be analyzed. This type of curve verification must be performed at least every 12 months. The values obtained must not vary by more than 10% of the known value for standard concentrations greater than or equal to 50 μg/L and must not vary by more than 25% of the known value for standard concentrations less than 50 μg/L. The overall correlation coefficient of the curve must be ≥0.995. If the stored program readings vary by more than the above acceptance criteria, the stored calibration program must not be used for quantitation until troubleshooting is carried out to determine and correct the source of error. Ref: Technical Assistance for Field Analysis of Total Residual Chlorine. Please send documentation of a passing curve with your response. Comment: While the overall correlation coefficient was a passing 0.997, the percent recovery of the 10 µg/L standard was not within the acceptable limits of ± 25% for standard concentrations of less than 50 µg/L. The individual standard limits of ± 25% for standard concentrations less than 50 µg/L and ± 10% for standard concentrations of 50 µg/L and greater were discussed during the inspection and spreadsheet to aid in the determination of whether or not the curve passes has been provided to the facility. Page 3 #5005 Lenoir County Public Schools D. Finding: Sample concentrations which are less than the concentration of the lowest calibration verification standard are being routinely reported on the Discharge Monitoring Report (DMR). Requirement: One of the standards must have a concentration equal to or below the lower reporting concentration for Total Residual Chlorine. Example: If the laboratory chooses to have a lower reporting limit of 100 μg/L for residual chlorine, you must analyze at least 100 µg/L or lower standard and report lower concentrations as < 100 μg/L or < the concentration of the chosen standard. Ref: Technical Assistance for Field Analysis of Total Residual Chlorine. E. Finding: The sample location is not being documented on the benchsheet. Requirement: Data pertinent to each analysis must be maintained for five years. Certified Data must consist of date collected, time collected, sample site, sample collector, and sample analysis time. The field bench sheets must provide a space for the signature or initials of the analyst, and proper units of measure for all analyses. Ref: 15A NCAC 02H .0805 (g) (1). IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing field testing records and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data were reviewed for February, March and April, 2010. 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: Todd Crawford Date: June 21, 2010 Report reviewed by: Tonja Springer Date: June 22, 2010