#624 inspection 2006

On-Site Inspection Report

LABORATORY NAME: e-Lab Analytical, Inc.

ADDRESS: 10450 Stancliff Rd.
Suite 210
Houston, TX 77099

CERTIFICATE NO: #624

DATE OF INSPECTION: 5/25-26/2006

TYPE OF INSPECTION: Initial

EVALUATOR: Mr. David G. Livingston

LOCAL PERSON(S) CONTACTED: David Pangrazio, Rebecca Hunt, Richard Sanchez, Laurence
Dioh, Raj Naran, Sunil Ajai, Kevin Given, Nick Vanlangendoch,
Johnny Allen, and Anthony Rodriguez

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 laboratory is spacious and well equipped. All facilities and equipment are well maintained.
Records are well kept and most data looked good. Some further quality control procedures need to be
implemented.

The laboratory QA officer mentioned adding parameters to the certified parameters list. To add a
parameter these steps need to be followed. Fill out and send in an amendment form. Send in any
MDL or IDOC studies if required. Send in acceptable PE samples for all additional parameters being
requested. Once this is complete, the North Carolina Laboratory Certification Program (NCLC) will
issue an invoice for the parameters of interest. Once the invoice is paid the parameters will be added
to your certified parameters list and a new certified parameters list will be mailed to your laboratory.

III. DEFICIENCIES, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:

GENERAL

COMMENT: The laboratory was unaware that NCLC recommends using a surrogate for method
504.1.

RECOMMENDATION: Recommended surrogates for EDB are Dibutyl Chlorendate,
2,4,5,6,Tetrachloro-meta-xylene, and Dichloropropane.

PROGRAM POLICIES

1) All North Carolina regulatory data for Waste Water must be reported on a dry weight basis.

2) Whenever a certified commercial laboratory refers or subcontracts samples to another certified
laboratory for analyses, the referring laboratory must supply the date and time samples were collected
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e-Lab Analytical, Inc.

to insure holding times are met. Subcontracted samples must clearly indicate the State of North
Carolina as the collection site on all record transcriptions. Laboratories may subcontract sample
fractions, extracts, leachates and other sample preparation products provided that all Rules and
requirements of 15A NCAC 02H .0800 are documented. The initial client requesting the analyses
must receive the original or a copy of the report made by the laboratory that performs the analyses.
Ref: 15A NCAC 2H .08005 (e) (2)

WALK THROUGH

COMMENT: The laboratory is not verifying the temperature probe of the pH or conductivity meters
on an annual basis. No need to respond, see note.

RECOMMENDATION: It is recommended that the temperature sensor be calibrated annually even
if not being used to report temperature.

REQUIREMENT: All thermometers must meet National Institute of Standards and Technology
(NIST) specifications for accuracy or be checked against a NIST traceable thermometer and
proper corrections made. Ref. 15A NCAC 2H .0805 (a) (7) (o).

Note: Done at the time of inspection.

(A) COMMENT: The laboratory was checking the balances quarterly but did not include a weight less
than 1 gram.

RECOMMENDATION: Add a weight in the milligram range to your quarterly check of the balances.

(B) COMMENT: The laboratory does not always check for Residual Chlorine content in samples
upon sample receipt.

REQUIREMENT: For any sample that requires the removal of residual chlorine, (8260, 8270,
8021, TKN, Ammonia, BOD, etc.) the laboratory must check to ensure that the chlorine has
been removed. The residual chlorine check must be performed to verify that the residual
chlorine level is below 0.5 mg/L. Commercially available starch iodide paper can be used to
perform this determination. Volatile samples are to be checked with a dedicated preservation
check vial or after sample analysis.

COMMENT: In order to verify that residual chlorine is not present in samples from a given
sample site, a site study of residual chlorine must be performed for each sample site. This
study must be available for review by the auditors.

ION CHROMATOGRAPHY

COMMENT: The laboratory limits for the MS/MSD (LFM/LFMD per method 300.0) pair were set
incorrectly at 75%-125%. No need to respond, see note.

REQUIREMENT: For part A of 300.0 the MS/MSD (LFM) limits are 80%-120%. Ref: EPA Method
300.0 9.4.3

Note: No data was out of control limits. The spreadsheet was corrected during the inspection.

CYANIDE
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e-Lab Analytical, Inc.

(C) COMMENT: The laboratory was not documenting the residual chlorine check and the sulfide
check.

REQUIREMENT: Begin documenting the residual chlorine and sulfide checks. Good laboratory
Practice: If it has not been documented it has not been done.

TOC

(1) DEFICIENCY: The laboratory is analyzing 3 replicates for method 9060.

REQUIREMENT: Quadruplicate analysis is required. Ref: Sw-846 EPA Method 9060 7.6

TCLP

(D) COMMENT: Samples are being spiked after preservation. The laboratory is spiking in the organic
preparation area or in the metals preparation areas.

REQUIREMENT: Matrix spikes are to be added after filtration of the TCLP extract and before
preservation. Ref: SW846 Method 1311 8.2.1 page 1311-19.

IV. PAPER TRAIL INVESTIGATION:

This consisted of comparing data with the values obtained on laboratory bench worksheets.

V. CONCLUSIONS:

Correcting the above cited deficiency and comments and implementing the requirements and
recommendations will help this lab to produce quality data and meet certification requirements.
Please respond to the numbered deficiency and lettered comments.

Report prepared by: David G. Livingston Date: 6/19/2006