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Home My WebLink About#5487_06_2014_final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5487 Laboratory Name: ECS Carolinas LLP Inspection Type: Field Maintenance Inspector Name(s): Todd Crawford Inspection Date: June 18, 2014 Date Report Completed: June 25, 2014 Date Forwarded to Reviewer: June 25, 2014 Reviewed by: Tonja Springer Date Review Completed: July 8, 2014 Cover Letter to use: Insp. Initial Insp. Reg. Insp. No Finding Insp. CP Corrected Unit Supervisor/Chemist III: Dana Satterwhite Date Received: 7/11/2014 Date Forwarded to Linda: 7/16/2014 Date Mailed: 7/16/2014 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: ECS Carolinas LLP NPDES PERMIT #: NC0023965 ADDRESS: 6714 Netherlands Dr. Wilmington, NC 28411 CERTIFICATE #: 5487 DATE OF INSPECTION: June 18, 2014 TYPE OF INSPECTION: Field Maintenance AUDITOR(S): Todd Crawford LOCAL PERSON(S) CONTACTED: Amy Conchas I. INTRODUCTION: This laboratory was inspected by a representative of the North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) program 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 also well organized and quickly retrieved upon request. Proficiency Testing (PT) samples for the 2014 proficiency testing calendar year have not yet been analyzed. The laboratory is reminded that these results must be submitted to this office directly from the vendor by September 30, 2014. Current quality assurance policies for Field Laboratories and approved procedures for the analysis of the facility’s currently certified parameters were provided at the time of the inspection. Contracted analyses are performed by Pace Analytical Services, Inc. (Certification #67). III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation Comment: Instrument identification for the meter used for Temperature, pH and Conductivity was not documented on the field logs. The NC WW/GW LC Approved Procedure for the Analysis of Temperature, NC WW/GW LC Approved Procedure for the Analysis of pH and NC WW/GW LC Approved Procedure for the Analysis of Conductivity documents state: The following must be documented in indelible ink whenever sample analysis is performed: Instrument identification. This requirement is a new policy that has been implemented by our program since the last inspection. Demonstration of acceptable corrective action (i.e., a new field parameter worksheet which identifies the meter) was received via email on June 18, 2014. No further response is necessary for this finding. Page 2 #5487 ECS Carolinas LLP Comment: The laboratory needed to increase the documentation of purchased materials and reagents. The Quality Assurance Policies for Field Laboratories document states: 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 information to analytical batches in which the solutions are used. This information 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. This requirement is a new policy that has been implemented by our program since the last inspection. Demonstration of acceptable corrective action (i.e., a traceability log sheet showing traceability information for all pH buffers and conductivity standards currently in-house) was received via email on June 18, 2014. No further response is necessary for this finding. A. Finding: Error corrections are not performed properly. Requirement: All documentation errors must be corrected by drawing a single line through the error so that the original entry remains legible. Entries shall not be obliterated by erasures or markings. Wite-Out®, correction tape or similar products designed to obliterate documentation are not to be used. Write the correction adjacent to the error. The correction must be initialed by the responsible individual and the date of change documented. All data and log entries must be written in indelible ink. Pencil entries are not acceptable. Ref: Quality Assurance Policies for Field Laboratories. pH – Standard Methods, 4500 H+B-2000 Comment: The field log did not include the units of measure. The North Carolina Administrative Code, 15A NCAC 02H .0805 (g) (1), states: “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. Notification of acceptable corrective action (i.e., a revised field sheet which shows the units of measure) was received via email on June 19, 2014. No further response is necessary for this finding. B. Finding: Values were reported to the client that exceeds the method specified accuracy of 0.1 units. Requirement: By careful use of a laboratory pH meter with good electrodes, a precision of ±0.02 unit and an accuracy of ±0.05 unit can be achieved. However, ± 0.1 pH unit represents the limit of accuracy under normal conditions, especially for measurement of water and poorly buffered solutions. For this reason, report pH values to the nearest 0.1 pH unit. Ref: Standard Methods, 4500 H+ B-2000, (6). Conductivity – Standard Methods, 5210 B-1997 Comment: The Automatic Temperature Compensator (ATC) had not been verified. The North Carolina Wastewater/Groundwater Laboratory Certification Approved Procedure for Analysis of Specific Conductance (Conductivity) states: 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. Demonstration of acceptable corrective action (i.e., documentation of an acceptable ATC check) was received via email on June 18, 2014. No further response is necessary for this finding. Page 3 #5487 ECS Carolinas LLP IV. PAPER TRAIL INVESTIGATION: No paper trail performed. Analyses performed are for a pre-treatment permit. No Discharge Monitoring Reports (DMRs) are submitted. All data reports are photocopied and sent to the client and to the Cape Fear Public Utility Authority. 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: Todd Crawford Date: June 23, 2014 Report reviewed by: Tonja Springer Date: July 8, 2014