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Home My WebLink About#5161 11-final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: #5161 Laboratory Name: Carolina Water Services, Inc. – Central Region Inspection Type: Field Commercial Maintenance Inspector Name(s): Jeffrey R. Adams Inspection Date: July 15, 2011 Date Report Completed: August 01, 2011 Date Forwarded to Reviewer: August 01, 2011 Reviewed by: Jason Smith Date Review Completed: August 8, 2011 Cover Letter to use: Insp. Initial X Insp. Reg. Insp. No Finding Insp. CP __ Corrected Unit Supervisor: Dana Satterwhite Date Received: August 9, 2011 Date Forwarded to Linda: August 15, 2011 Date Mailed: August 15, 2011 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Carolina Water Services, Inc. – Central Region NPDES PERMIT #: NC0038831; NC0051322; NC0062219; NC0064378; NC0061638; NC0085111; NC0086266; NC0077101 ADDRESS: 315-B Hwy 70 East Garner, NC 27529 CERTIFICATE #: 5161 DATE OF INSPECTION: July 15, 2011 TYPE OF INSPECTION: Field Commercial Maintenance AUDITOR(S): Jeffrey R. Adams LOCAL PERSON(S) CONTACTED: Kerry Walton 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 was clean and well organized. The facility has all the equipment necessary to perform the analyses. Records were maintained and well organized, however, some quality control procedures need to be implemented. The laboratory was given a packet containing North Carolina Laboratory Certification quality control requirements and policies during the inspection. Finding A is a new policy that has been implemented by our program since the last inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Traceability A. 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 (where specified). 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 primary standards, chemicals, reagents, and materials used for a period of five years. Consumable materials such as pH buf fers, lots of pre-made standards and/or media, solids and bacteria filters, etc. are included in this requirement. Ref: Quality Assurance Policies for Field Laboratories. Page 2 #5161 Carolina Water Services, Inc. – Central Region Dissolved Oxygen – Standard Methods, 18th Edition, 4500 O G Recommendation: The yellow sponge in the probe storage well was dirty and needed changing. A light colored sponge is used in the storage chamber to discern cleanliness and must be changed when it becomes dirty to prevent issues with contamination. It is recommended the lab consult the Dissolved Oxygen (DO) probe owner’s manual for instructions on probe storage and cleanliness. Comment: If the membrane is coated with oxygen consuming (e.g., bacteria) or oxygen evolving organisms (e.g., algae), erroneous readings may occur. Ref: YSI Operators Manual pg. (7) (4.5) (2). YSI 1/07. Dissolved Oxygen – Standard Methods, 18th Edition, 4500 O G pH – Standard Methods, 18th Edition, 4500 H+ B Recommendation: The laboratory is posting the temperature sensor correction on the pH and DO meters as required. It is recommended that the laboratory also document the date NIST sensor checks were performed and the analyst initials with the temperature correction. pH – Standard Methods, 18th Edition, 4500 H+ B B. Finding: The laboratory is citing the wrong units of measure on the benchsheet (i.e., mg/L). 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 benchsheets 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). An updated benchsheet must be submitted with the response to this report. Comment: Although the laboratory was citing the wrong units of measure for pH on the benchsheets, the data was being reported correctly (i.e., in S.U.) on the Discharge Monitoring Reports (DMRs). Total Residual Chlorine – HACH Method 10025 ULR (Amperometric Titration) Comment: During the audit, the laboratory indicated that they are in the process of switching from the amperometric titration technology to the DPD spectrophotometric technology. A response is required for each finding in this subsection. Note: Findings D, E and F apply to both the amperometric and spectrophotometric technologies. Finding C does not apply to the DPD spectrophotometric technology for field laboratories; however, the laboratory must meet this requirement as long as the amperometri c method is employed. C. Finding: The laboratory is not analyzing a sample spike each day samples are analyzed. Requirement: The laboratory must analyze a sample spike each day samples are analyzed. Ideally, the percent recovery should be 100%. Generally, results from 80 – 120% recovery are considered acceptable. Ref: HACH Water Analysis Handbook, Amperometric Back Titration Method 10025, pg. 8. Recommendation: It is recommended that the laboratory also analyze a blank spike each day using the same standard solution at the same concentration as is used in the sample spike. This will serve as a check of the spiking solution should a failure occur with the sample spike. If Page 3 #5161 Carolina Water Services, Inc. – Central Region the sample spike fails the quality control criterion, but the blank spike passes t he criterion, then it may be concluded that the sample spike failure is attributed to sample matrix. D. Finding: The laboratory is not recording units of measure (i.e., µg/L) 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 benchsheets 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). An updated benchsheet must be submitted with the response to this report. E. Finding: The laboratory is not documenting sample collection and analysis times on the benchsheets. 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 benchsheets must provide a space for the signature or initials of t he analyst, and proper units of measure for all analyses. Ref: 15A NCAC 02H .0805 (g) (1). An updated benchsheet must be submitted with the response to this report. F. Finding: The laboratory is not documenting the electrode slope response adjustment (instrument calibration for spectrophotometric method) and the date and times the electrode slope response adjustments (calibrations) are performed on laboratory benchsheets. Requirement: Note the LED reading on the Amperometric Titrator. Unlock the BIAS control knob until a stable reading between 0.50 and 0.60 is obtained. Lock the bias control. The adjustment of the electrode response slope is complete. Ref: Hach Water Analysis Handbook, Amperometric Back Titration Method 10025, pg. 2. An updated benchsheet must be submitted with the response to this report. Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A NCAC 2H .0805 (g) (1). Comment: The following references apply to spectrophotometric calibration and must be followed once the spectrophotometric technology is employed: A record of instrument calibration where applicable must be filed in an orderly manner so as to be readily available for inspection upon request. Ref: 15A NCAC 02H .0805 (g) (2). The time the instrument is calibrated must be documented. Ref: Technical Assistance for Field Analysis of Total Residual Chlorine. 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 Kings Grant (NPDES permit #NC0062219), Amherst (NPDES permit #NC0061638), Carolina Trace Utilities (NPDES permit #NC0038831), Ashley Hills (NPDES permit #NC0051322), and Willowbrook (NPDES permit #NC0064378) for March, April and May, 2011. The following errors were noted. King’s Grant – pH was recorded on benchsheet as being analyzed on 3/8/11, but was recorded on DMR as analyzed on 3/7/11. Page 4 #5161 Carolina Water Services, Inc. – Central Region Willowbrook – Dissolved Oxygen was recorded on benchsheet as being analyzed on 5/5/11, but was recorded on DMR as analyzed on 5/3/11. In order to avoid questions of legality, it is recommended that you contact the appropriate Regional Office for guidance as to whether an amended Discharge Monitoring Report will be required. A copy of this report will be forwarded to the Regional Office. 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: Jeffrey R. Adams Date: August 01, 2011 Report reviewed by: Jason Smith Date: August 8, 2011