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HomeMy WebLinkAbout#5594 11-final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: #5594 Laboratory Name: Solutions - IES, Inc. Inspection Type: Field Commercial Initial Inspector Name(s): Jeffrey R. Adams Inspection Date: July 14, 2011 Date Report Completed: July 22, 2011 Date Forwarded to Reviewer: July 22, 2011 Reviewed by: David Livingston Date Review Completed: July 27, 2011 Cover Letter to use: X Insp. Initial Insp. Reg. Insp. No Finding Insp. CP __ Corrected Unit Supervisor: Dana Satterwhite Date Received: July 29, 2011 Date Forwarded to Alberta: August 1, 2011 Date Mailed: August 1, 2011 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Solutions - IES , Inc. NPDES PERMIT #: Various ADDRESS: 1101 Nowell Road Raleigh, NC 27607 CERTIFICATE #: 5594 DATE OF INSPECTION: July 14, 2011 TYPE OF INSPECTION: Field Commercial Initial AUDITOR(S): Jeffrey R. Adams LOCAL PERSON(S) CONTACTED: Kathryn Doll and Tony Lieberman 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 laboratory is not performing any compliance sampling and/or monitoring at this time. The laboratory is only monitoring groundwater samples prior to collection; therefore, no regulatory data has been generated with the exception of Proficiency Testing (PT) samples. Records were well organized; however, some quality control procedures need to be implemented. Proficiency testing samples have been analyzed for all certified parameters for the 2011 proficiency testing calendar year and the graded results were 100% acceptable. This is the first inspection of this laboratory facility. The laboratory was given a packet containing North Carolina Laboratory Certification quality control requirements and policies during the 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. 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 Page 2 #5594 Solutions – IES, Inc. 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. NIST Traceable Thermometer B. Finding: The certification of the National Institute of Standards and Technology (NIST) traceable thermometer, used to perform the annual NIST sensor checks, had expired. Requirement: NIST traceable thermometers used for temperature measurement must be recalibrated in accordance with the manufacturer’s recalibration date. If no recalibration date is given, the NIST traceable thermometer must be recalibrated annually. Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy. A copy of the new certificate must be submitted with the response to this report. The temperature sensors must be rechecked using the new traceable thermometer and a copy of the checks must be submitted with the response to this report. Comment: The laboratory used an Oakton digital thermometer, but no documentation was available to determine when the device was purchased and when the NIST traceable certification had expired. 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. Conductivity – Standard Methods, 18th Edition, 2510 B C. 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: Technical Assistance for Field Analysis of Specific Conductance. Please refer to the Technical Assistance document for field analysis of Specific Conductance for instructions on performing this check. A copy of the ATC verification must be submitted with the response to this report. Conductivity – Standard Methods, 18th Edition, 2510 B Dissolved Oxygen – Standard Methods 18th Edition, 4500 O G pH – Standard Methods, 18th Edition, 4500 H+ B D. Finding: The annual NIST sensor checks on laboratory instrument temperature sensing devices (i.e., Conductivity, DO and pH meters) were performed using a thermometer with an expired calibration verification. Page 3 #5594 Solutions – IES, Inc. Requirement: The temperature sensor in the meter must be checked every 12 months against an NIST certified or NIST traceable thermometer and the process documented even if the instrument is not used for reporting temperature results. The documentation must include the serial number of the NIST certified thermometer or NIST traceable thermometer that was used in the comparison. The temperature correction (even if it is zero) must be posted on the meter as well as in hard copy format (to be retained for 5 years). Ref: Technical Assistance for Field Analysis of Dissolved Oxygen, Technical Assistance for Field Analysis of pH, and Technical Assistance for Field Analysis of Conductivity. E. Finding: The laboratory is not posting the temperature correction on the YSI 56 MPS multi-probe meter used for Conductivity, DO and pH. Requirement: All temperature sensing devices on meters must be calibrated against a NIST certified or NIST traceable thermometer annually (every 12 months) and proper corrections made and documented. The meter reading must be less than 1ºC from the NIST certified reading to be acceptable. Document the serial number and manufacturer of the NIST thermometer that was used in the comparison. Document any correction that applies (even if zero) on both the meter and on a separate sheet to be filed. Ref: Technical Assistance for Field Analysis of Dissolved Oxygen, Technical Assistance for Field Analysis of pH, and Technical Assistance for Field Analysis of Conductivity. F. Finding: The laboratory is not recording units of measure (i.e., µS/cm for Conductivity, mg/L for D.O. and S.U. for pH) or the sample collection times on laboratory 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 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. G. Finding: The laboratory is not documenting the instrument calibrations and the time calibrations are performed on laboratory benchsheets. Requirement: 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). An updated benchsheet must be submitted with the response to this report. Dissolved Oxygen – Standard Methods, 18th Edition, 4500 O G H. Finding: The laboratory is not performing and documenting the air calibration prior to analysis. Requirement: The meter must be calibrated prior to analysis of samples. The meter must be calibrated either by the air calibration method or according to the manufacturer's calibration procedure. The laboratory must document each time that a calibration is performed. Depending upon the instrument used and type of calibration performed, calibration documentation may be accomplished by recording elevation and temperature or barometric pressure (in psi) or salinity or by simply recording a final reading (in mg/L) for instruments that auto calibrate. Ref: Technical Assistance for Field Analysis of Dissolved Oxygen. Comment: The laboratory should use moist air for the air calibration. This is accomplished by calibrating the electrode in an environment with a high relative humidity. Using dry air for the Page 4 #5594 Solutions – IES, Inc. calibration can result in errant readings. When performing analysis at multiple sampling locations, re-calibration(s) must be performed every four hours. pH – Standard Methods, 18th Edition, 4500 H+ B I. Finding: The laboratory is not performing and documenting a calibration check after each calibration. Requirement: In addition to the calibration standards, the meter must be verified with a third calibration standard (e.g., pH 7 buffer). If compliance samples are analyzed throughout the day, a post calibration check (e.g., pH 7 buffer) must be analyzed mid-day and at the end of the run (i.e., roughly every 4 hours based on an eight hour day). Ref: Technical Assistance for Field Analysis of pH. Copies of completed calibration records with the calibration check documented must be submitted with the response to this report. IV. PAPER TRAIL INVESTIGATION: No paper trail performed. V. CONCLUSIONS: Correcting the above-cited findings 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: July 22, 2011 Report reviewed by: David Livingston Date: July 27, 2011