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HomeMy WebLinkAbout#610-final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 610 Laboratory Name: Environment 1, Inc. Mobile Laboratory Inspection Type: Commercial Maintenance Inspector Name(s): Todd Crawford, Gary Francies, Dana Satterwhite Inspection Date: July 29, 2010 Date Report Completed: August 24, 2010 Date Forwarded to Reviewer: August 24, 2010 Reviewed by: Gary Francies Date Review Completed: 9/3/2010 Cover Letter to use: Insp. Initial X Insp. Reg. Insp. No Finding Insp. CP Unit Supervisor: Dana Satterwite Date Received: September 3, 2010 Date Forwarded to Alberta: September 10, 2010 Date Mailed: September 10, 2010 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Environment 1, Inc. Mobile Laboratory NPDES PERMIT #: N/A ADDRESS: P.O. Box 7085 Greenville, NC 27835 CERTIFICATE #: 610 DATE OF INSPECTION: July 29, 2010 TYPE OF INSPECTION: Commercial Maintenance AUDITOR(S): Todd Crawford, Gary Francies and Dana Satterwhite LOCAL PERSON(S) CONTACTED: Mark Oliveira and Chad Davis 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: This inspection was requested by the Division of Water Quality (DWQ), Environmental Sciences Section (ESS). Their review of recent fecal coliform data led them to theorize that there was a possible low bias in the laboratory’s data. Similar concerns had been expressed prior to the last inspection in 2008. An environmental sample was collected for analysis and split between the Environment 1, Inc. mobile lab and the DWQ lab for comparison. Carrie Ruhlman, Monitoring Coalition Coordinator with ESS, and Carol Bell with the Yadkin/Pee Dee River Basin Association were on hand to observe. Finding A is a new policy that has been implemented by our program since the last inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Comment: Due to scheduling, the field meters were not available for inspection during this audit. Documentation Recommendation: It is recommended that the serial number of the National Institute of Standards and Technology (NIST) thermometer used to check the field meters’ temperature sensors be documented. Recommendation: It is recommended that Standard Operating Procedures (SOPs) be reviewed annually to ensure that they accurately reflect the procedures in use. Document both the review and revision dates on the SOP. #610 Environment 1 Inc., Mobile Laboratory Page 2 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 so that they are traceable to the analytical batches in which these items are used. 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 (where specified). 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 primary standards, chemicals, reagents, and materials used for a period of five years. Consumable materials such as pH buffers, lots of pre-made standards and/or media, solids and bacteria filters, etc. are included in this requirement. Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy. Coliform, Fecal (MF) – Standard Methods, 18th Edition, 9222 D Comment: It was stated that, in May, the analyst began transporting media in a flask instead of in poured plates. The SOP needs to be updated to reflect this change. The North Carolina Administrative Code, 15A NCAC 2H .0805 (a) (7) states: Each laboratory shall develop and maintain a document outlining the analytical quality control practices used for the parameters included in their certification. Supporting records shall be maintained as evidence that these practices are being effectively carried out. Comment: One possible theory for the seemingly low bias for results was that the temperatures in the portable incubator might not be holding steady in the narrow range required. The analyst stated that incubator temperatures are checked three times per day. Recommendation: It is recommended that the location of the incubator thermometer be rotated so that temperatures are alternately checked on the top, middle and bottom shelf locations. Recommendation: It is recommended that on days when media is replenished, a duplicate sample be analyzed; one with the old media and one with the new media. Recommendation: It is recommended, as an extra measure of confidence, that a MPN confirmation of the “non-fecal” colonies be performed to insure that only true fecal colonies are being counted. Recommendation: It is recommended that a 1 ml serological pipette be used for dispensing 1 ml sample aliquots (paying careful attention to whether the pipette is a “to contain” or “to deliver” pipette) instead of drawing up 11 ml in a larger pipette and dispensing it down to the 10 ml mark. This will insure a more consistent and accurate volume delivery. Recommendation: It is recommended that the sample bottle be shaken between each aliquot draw to better insure sample homogeneity. B. Finding: Forceps are not being properly sterilized in between each sample filter handling. Requirement: Sterilize before use by dipping in 95% ethyl or absolute methyl alcohol and flaming. Ref: Standard Methods, 18th Edition, 9020 B. (2) (l) and 9222 B. (1) (i). Comment: It was observed that a series of sample filters were removed from the filter apparatus without sterilizing the forceps between each one. #610 Environment 1 Inc., Mobile Laboratory Page 3 C. Finding: Consumable testing of M-FC Media is not being consistently carried out. Requirement: It is required that when a new lot of culture medium, pads, or membrane filters is to be used, a comparison of the current lot in use (reference lot) against the new lot (test lot), be made. As a minimum, make single analyses on five positive water samples. Ref: Standard Methods, 18th Edition, 9020 B. (3) (d). IV. PAPER TRAIL INVESTIGATION: No paper trail performed. V. CONCLUSIONS: Correcting the above-cited findings and implementing the recommendations will help this lab to produce quality data and meet certification requirements. The inspectors 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: August 24, 2010 Report reviewed by: Gary Francies Date: September 3, 2010