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Home My WebLink About#244-final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 244 Laboratory Name: Guilford East, Inc. WWTP Laboratory Inspection Type: Industrial Maintenance Inspector Name(s): Todd Crawford Inspection Date: May 24, 2011 Date Report Completed: June 6, 2011 Date Forwarded to Reviewer: June 6, 2011 Reviewed by: Tonja Springer Date Review Completed: June 7, 2011 Cover Letter to use: ___ Insp. Initial X Insp. Reg. Insp. No Finding Insp. CP Unit Supervisor: Dana Satterwhite Date Received: June 7, 2011 Date Forwarded to Alberta: June 17, 2011 Date Mailed: June 20, 2011 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Guilford East, Inc. WWTP Laboratory ADDRESS: P.O. Box 509 Kenansville, NC 28349 CERTIFICATE #: 244 DATE OF INSPECTION: May 24, 2011 TYPE OF INSPECTION: Industrial Maintenance AUDITOR(S): Todd Crawford LOCAL PERSON(S) CONTACTED: Keith Westbrook and Jeff 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 laboratory was well equipped, neatly organized and clean. The staff was extremely helpful and professional. Some improvements in documentation need to be implemented. The requirements associated with Findings A and B are new since the last inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation Recommendation: It is recommended that all benchsheets be updated to reflect that the methods followed are from the 20th Edition of Standard Methods. A. Finding: The preparation of standards and reagents are not documented in such a way as to provide a traceable history from analysis to manufacturer. 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 buffers, lots of pre-made standards and/or media, solids and bacteria filters, etc. are included in this requirement. Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy. Page 2 #244 Guilford East, Inc. WWTP Laboratory Quality Control B. Finding: The Standard Operating Procedures (SOPs) have not been routinely reviewed and/or updated. Requirement: Each laboratory shall develop and maintain a document outlining the analytical quality control practices used for the parameters included in their certification. Supporting records shall be maintained as evidence that these practices are being effectively carried out. The quality control document shall be available for inspection by the State Laboratory. Ref: 15A NCAC 2H .0805 (a) (7). Submit the updated SOPs for review by October 31, 201 1. A written response is required. C. Finding: The analytical balance weights have not been verified against ASTM standard weights in the past 5 years. Requirement: ASTM Class 1 and 2 weights must be verified at least every 5 years. ASTM Class 1 weights (20 g to 25 kg) and ASTM Class 2 weights (10 g to 1 mg) are equivalent to the NBS Class S weights specified in 15A NCAC 2H .0805 (a) (7) (K). Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy. Biochemical Oxygen Demand – Standard Methods, 18th Edition, 5210 B Recommendation: It is recommended that the Dissolved Oxygen (D.O.) meter drift check be documented on the Biochemical Oxygen Demand (BOD) benchsheet instead of the D.O. calibration sheet so as to be better associated with the BOD analyses. D. Finding: The analyst stated that although QC failures were rare, associated results were not qualified on Discharge Monitoring Reports (DMRs). Requirement: When quality control (QC) failures occur, the laboratory must attempt to determine the source of the problem and must apply corrective action. If data qualifiers are used to qualify samples not meeting QC requirements, the data may not be useable for the intended purposes. 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: North Carolina Wastewater/Groundwater Laboratory Certification Policy based upon Standard Methods, 20th Edition, 1020 B. (14). Residue, Suspended – Standard Methods, 18th Edition, 2540 D E. Finding: The sample collection time is not clearly documented on the benchsheet. This is considered pertinent information. Requirement: All analytical data pertinent to each certified analysis must be filed in an orderly manner so as to be readily available for inspection upon request. Ref: 15A NCAC 2H .0805 (a) (7) (A). F. Finding: Filters are not weighed to constant weight prior to sample analysis, nor is a dry filter blank analyzed with each set of samples. Requirement: If pre-prepared filters are not used, the method requires that filters must be weighed to a constant weight after washing. Repeat cycle of drying, cooling, desiccating, and Page 3 #244 Guilford East, Inc. WWTP Laboratory weighing until a constant weight is obtained or until weight change is less than 4% of the previous weighing or 0.5 mg, whichever is less. In lieu of this process, it is acceptable to analyze a single daily dry filter blank to fulfill the method requirement of drying all filters to a constant weight prior to analysis. Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy based upon Standard Methods 20th Edition 2540 D. (3) (a). G. Finding: No minimum dried residue weight gain is being used, resulting in the incorrect reporting of the final results. Requirement: The minimum weight gain allowed by any approved method is 2.5 mg. Choose sample volume to yield between 2.5 and 200 mg dried residue. This establishes a minimum reporting value of 2.5 mg/L when 1000 mL of sample is analyzed. If complete filtration takes more than 10 minutes increase filter diameter or decrease sample volume. In instances where the weight gain is less than the required 2.5 mg, the value must be reported as less than the appropriate value based upon the volume used. Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy based upon Standard Methods, 20th and 21st Editions, 2540 D. (3) (b). Comment: This establishes a minimum reporting value of 2.5 mg/L when 1000 mL of sample is analyzed. W hen less than 2.5 mg of residue is obtained, the final result is based on the volume of sample filtered. For example, if 50 mL of sample is filtered and < 2.5 mg of dried residue is obtained, the value reported would be < 50 mg/L. Comment: The lab is currently filtering 50 mL of sample through 24mm glass microfiber filters and consistently getting less than 1 mg of dried residue. It was stated that the small volume was due to the length of time (sometimes as much as 10 minutes) that the filtering took and that more than 50 mL simply would not pass through the filter. Recommendation: It is recommended that the filter size be increased so that at a volume of sample sufficient to yield the required 2.5 mg of dried residue can be filtered in less than 10 minutes. Conductivity – Standard Methods, 20th Edition, 2510 B H. Finding: The Automatic Temperature Compensator (ATC) has not been verified. Requirement: The ATC must be verified annually (i.e., every twelve months) and the process documented. The ATC must be verified by analyzing a standard at 25 °C (the temperature that conductivity values are compensated to) and a temperature(s) that brackets the temperature ranges of the samples to be analyzed. This may require the analysis of a third temperature reading that is > 25 °C. Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy. Temperature – Standard Methods, 20th Edition, 2550 B I. Finding: The dial-type thermometer used to measure temperature for reporting has not been calibrated against a NIST thermometer. Requirement: All thermometers must meet NIST specifications for accuracy or checked, at a minimum annually, against a NIST traceable thermometer and proper corrections made. Ref: 15A NCAC 2H .0805 (a) (7) (O). Page 4 #244 Guilford East, Inc. WWTP Laboratory Comment: You may have trouble getting your NIST thermometer re-certified. As part of an initiative to reduce the use of mercury in products, EPA is working with stakeholders to reduce the use of mercury-containing non-fever thermometers in industrial and commercial settings. The National Institute of Standards and Technology (NIST), which is working with EPA on this effort, announced on February 2, 2011 that it will no longer calibrate mercury-in-glass thermometers for traceability purposes beginning on March 1, 2011. Other vendors may follow this lead. Additional information on the phase-out of mercury-filled thermometers and selecting alternatives to mercury-filled thermometers can be found on the following EPA website: http://www.epa.gov/hg/thermometer.htm. pH – Standard Methods, 20th Edition, 4500 H+ B J. Finding: The proper units of measure are not being documented. This is considered pertinent information. Requirement: All laboratories must use printed laboratory bench worksheets that include a space to enter the signature or initials of the analyst, date of analyses, sample identification, volume of sample analyzed, value from the measurement system, factor and final value to be reported and each item must be recorded each time samples are analyzed. The date and time BOD and Coliform samples are removed from the incubator must be included on the laboratory worksheet. Ref: 15A NCAC 2H .0805 (a) (7) (H). Dissolved Oxygen – Standard Methods, 20th Edition, 4500 O G K. Finding: The temperature sensor on the HACH 40d Multi-meter has not been calibrated against a NIST thermometer. Requirement: All thermometers must meet NIST specifications f or accuracy or checked, at a minimum annually, against a NIST traceable thermometer and proper corrections made. Ref: 15A NCAC 2H .0805 (a) (7) (O). IV. PAPER TRAIL INVESTIGATION: No paper trail performed. 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 6, 2011 Report reviewed by: Tonja Springer Date: June 6, 2011