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Home My WebLink About#5634_11_2014_Insp_final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5634 Laboratory Name: Chad Watkins Company Inspection Type: Field Commercial Initial Inspector Name(s): Todd Crawford Inspection Date: 11/5/2014 Date Report Completed: 11/6/2014 Date Forwarded to Reviewer: 11/6/2014 Reviewed by: Nick Jones Date Review Completed: 11/6/2014 Cover Letter to use: Insp. Initial Insp. Reg. Insp. No Finding Insp. CP Corrected Insp. Reg. Delay Unit Supervisor/Chemist III: Dana Satterwhite Date Received: 11/6/2014 Date Forwarded to Linda: 11/12/2014 Date Mailed: 11/12/2014 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Chad Watkins Company ADDRESS: 3200 Wilmington Hwy Jacksonville, NC 28540 CERTIFICATE #: 5634 DATE OF INSPECTION: November 5, 2014 TYPE OF INSPECTION: Field Commercial Initial AUDITOR(S): Todd Crawford LOCAL PERSON(S) CONTACTED: Chad Watkins 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: This was the laboratory’s first inspection. The facility has all the equipment necessary to perform the analyses. A system for traceability of reagents was in place but did not include all the reagents in use. Proficiency Testing (PT) samples have been analyzed for all certified parameters for the 2014 proficiency testing calendar year and the graded results were 100% acceptable. Contracted analyses are performed by Beacham Laboratory (Certification #1). 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. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation Recommendation: The facility is identified on the benchsheet with the NDPES permit number. It is recommended that the facility name (i.e., Cabin Creek WWTP) also be added for ease of identification. 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. Page 2 #5634 Chad Watkins Company Comment: Corrections were made by obliterating the error. B. Finding: The laboratory needs to increase the documentation of purchased reagents. 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 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. Comment: pH buffers and Total Residual Chlorine (TRC) gel standard information was documented but TRC buffer and DPD color reagent information was not. Proficiency Testing C. Finding: The preparation of TRC Proficiency Testing (PT) samples is not documented. Requirement: PT samples received as ampules must be diluted according to the PT provider’s instructions. The preparation of PT samples must be documented in a traceable log or other traceable format. The diluted PT sample becomes a routine environmental sample and is added to a routine sample batch for analysis. Ref: Proficiency Testing Requirements, February 20, 2012, Revision 1.2. Comment: Dating and initialing the instruction sheet for the preparation of the TRC PT would satisfy the documentation requirement. D. Finding: The laboratory is not documenting PT sample analyses in the same manner as environmental samples. Requirement: All PT sample analyses must be recorded in the daily analysis records as for any environmental sample. This serves as the permanent laboratory record. Ref: Proficiency Testing Requirements, February 20, 2012, Revision 1.2. Comment: The analysis of PT samples is designed to evaluate the entire process used to routinely report environmental analytical results; therefore, PT samples must be analyzed and the process documented in the same manner as environmental samples. pH – Standard Methods, 4500 H+ B-2000 Temperature – Standard Methods, 2550 B-2000 Dissolved Oxygen – Standard Methods, 4500 O G-2001 Total Residual Chlorine – Hach 10014 (ULR) E. Finding: The laboratory benchsheet was lacking pertinent data: Instrument identification. Requirement: The following must be documented in indelible ink whenever sample analysis is performed: Instrument Identification. Ref: NC WW/GW LC Approved Procedure for the Analysis of pH, NC WW/GW LC Approved Procedure for the Analysis of Temperature, NC WW/GW LC Page 3 #5634 Chad Watkins Company Approved Procedure for the Analysis of Dissolved Oxygen, NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine. F. Finding: The analyst is not signing or initialing 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 analytes. Ref: 15A NCAC 2H .0805 (g) (1). Comment: The benchsheet had the analyst’s name printed on it but it was not actually signed or initialed. A handwritten signature or initial is required to verify the data produced. pH – Standard Methods, 4500 H+ B-2000 G. Finding: The laboratory benchsheet was lacking pertinent data: Units of measure. 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). Comment: The unit of measure for pH is Standard Units, abbreviated as S.U. H. Finding: Values were reported that exceed 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). Total Residual Chlorine – HACH 10014 (ULR) Comment: The DPD and buffer reagents were both expired. The Quality Assurance Policies for Field Laboratories document states: Adherence to manufacturer expiration dates is required. Chemicals, reagents, standards, consumables exceeding the expiration date can no longer be considered reliable. If the expiration is only listed as a month and year (with no specific day of the month), the last day of the month will be considered the actual date of expiration. Monitor materials for changes in appearance or consistency. Any changes may indicate potential contamination and the item should be discarded, even if the expiration date is not exceeded. If no expiration date is given, the laboratory must have a policy for assigning an expiration date. If no date received or expiration date can be determined, the item should be discarded. Demonstration of acceptable corrective action (i.e., all expired reagents were thrown away and reagents that were within their expiration dates brought out and put into use) was performed during the inspection. No further response is necessary for this finding. I. Finding: The laboratory benchsheet was lacking pertinent data: Meter calibration time. Requirement: The following must be documented in indelible ink whenever sample analysis is performed: Meter calibration and meter calibration time(s). Ref: NC WW/GW LC Approved Procedure for the Analysis of Total residual Chlorine. Page 4 #5634 Chad Watkins Company 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 Resources. Data were reviewed for Cabin Creek Campground & RV Park WWTP (NC0034339) for July, August and September, 2014. No transcription errors were detected. The facility appears to be doing a good job of accurately transcribing data. V. CONCLUSIONS: Correcting the above-cited findings and implementing the recommendation 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: November 6, 2014 Report reviewed by: Nick Jones Date: November 6, 2014