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INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #: #5328
Laboratory Name: Clarke Utilities, Inc.
Inspection Type: Field Commercial Maintenance
Inspector Name(s): Jeffrey R. Adams
Inspection Date: May 19, 2011
Date Report Completed: May 24, 2011
Date Forwarded to Reviewer: May 24, 2011
Reviewed by: Todd Crawford
Date Review Completed: June 3, 2011
Cover Letter to use: Insp. Initial Insp. Reg. Insp. No Finding X Insp. CP ___ Corrected
Unit Supervisor: Dana Satterwhite
Date Received: June 6, 2011
Date Forwarded to Alberta: June 17, 2011
Date Mailed: June 20, 2011
_____________________________________________________________________
On-Site Inspection Report
LABORATORY NAME: Clarke Utilities, Inc.
NPDES PERMIT #: NC0663746, NC0073318
ADDRESS: 223 Hwy 70 East
East Pointe Suite 115
Garner, NC 27529
CERTIFICATE #: 5328
DATE OF INSPECTION: May 19, 2011
TYPE OF INSPECTION: Field Commercial Maintenance
AUDITOR(S): Jeffrey R. Adams
LOCAL PERSON(S) CONTACTED: Joel Clarke
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 according to the appropriate retention
schedule and well organized, however, some quality control procedures need to be
implemented. As a reminder, the 2011 PT samples are due no later than October 31,
2011.
The laboratory was given a packet containing North Carolina Laboratory Certification
quality control requirements and policy 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:
Documentation
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,
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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.
pH – Standard Methods, 18th Edition, 4500 H+ B
B. Finding: The laboratory is not recording units of measure 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).
pH – SW-846 Method 9045 D
Recommendation: The laboratory was certified for SW -846 9045 D, which is used
when the sample contains < 20% moisture content. It was recommended that the
laboratory amend the certificate attachment to include certification for SW -846 Method
9040 C for use when the sample contains a moisture content of > 20%. The laboratory
has submitted an Amendment to Certification Application requesting addition of
SW-846 9040C since the inspection.
C. Finding: The pH meter was not calibrated with standards that bracketed the range
of the sample measurements encountered. Cited previously on 11/19/08.
Requirement: Each instrument/electrode system must be calibrated at a
minimum of two points that bracket the expected pH of the samples and are
approximately three pH units or more apart. (For corrosivity characterization, the
calibration of the pH meter should include a buffer of pH 2 for acidic wastes and
a pH 12 buffer for caustic wastes; also, for corrosivity characterization, the
sample must be measured at 25 ± 1 ºC if the pH of the waste is above 12.0.)
Various instrument designs may involve use of a dial (to “balance” or
“standardize”) or a slope adjustment, as outlined in the manufacturer’s
instructions. Repeat adjustments on successive portions of the two buffer
solutions until readings are within 0.05 pH units of the buffer solution value. Ref:
EPA SW -846 Test Methods for Evaluating Solid Waste, Physical/Chemical
Methods; 3rd Edition, Method 9045 D, Rev. 4, November 2004, Section 7.1.2.
Comment: These same bracketing requirements also apply to SW -846 Method
9040 C.
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Total Residual Chlorine – Standard Methods, 18th Edition, 4500 Cl G
D. Finding: The calibration verification standard has not been assigned a true
value.
Requirement: Purchased “Gel-type” or sealed liquid ampoule standards may be
used for daily calibration verification only. These standards must be verified initially
and every 12 months thereafter, with the standard curve. Note: 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. Refer to the Technical
Assistance for the Field Analysis of Total Residual Chlorine provided during
the inspection.
E. Finding: The laboratory is not documenting the time the check standard is
analyzed.
Requirement: The time the check standard is analyzed 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 Deer Chase subdivision (NPDES permit #NC0663746)
and Whipporwill Valley subdivision (NPDES permit #NC0073318) for January, February
and March, 2011. No transcription errors were detected. The facility appears to be doing
a good job of accurately transcribing data.
V. CONCLUSIONS:
We are concerned with the finding that was cited previously and not corrected.
Laboratory Decertification Ref: 15A NCAC 2H .0807 (a) (1), (13) and (14):
A laboratory may be decertified for any or all parameters for up to one year for any or all
of the following infractions:
(1) Failing to maintain the facilities, or records, or personnel, or equipment, or quality
control program as set forth in the application, and these Rules; or
(13) Failing to respond to requests for information by the date due; or
(14) Failing to comply with any other terms, conditions, or requirements of this
Section or of a Laboratory certification.
Correcting the above-cited findings and implementing the recommendations will help
this lab to produce quality data and meet certification requirements. Please respond to
all findings.
Report prepared by: Jeffrey R. Adams Date: May 24, 2011
Report reviewed by: Todd Crawford Date: June 3, 2011