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HomeMy WebLinkAbout#5328 11-final 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, Page 2 #5328 Clarke Utilities, Inc. 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. Page 3 #5328 Clarke Utilities, Inc. 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