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HomeMy WebLinkAbout#638_11_2014_final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 638 Laboratory Name: Aquatic Ecology Lab – UNCW Center for Marine Science Inspection Type: Commercial Maintenance Inspector Name(s): Todd Crawford Inspection Date: November 12, 2014 Date Report Completed: November 25, 2014 Date Forwarded to Reviewer: November 25, 2014 Reviewed by: Beth Swanson Date Review Completed: December 1, 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: 12/1/2014 Date Forwarded to Linda: 12/3/2014 Date Mailed: 12/4/2014 _____________________________________________________________________ cc: Carrie Ruhlman On-Site Inspection Report LABORATORY NAME: Aquatic Ecology Lab – UNCW Center for Marine Science ADDRESS: 5600 Marvin Moss Lane Wilmington, NC 28409 CERTIFICATE #: 638 DATE OF INSPECTION: November 12, 2014 TYPE OF INSPECTION: Commercial Maintenance AUDITOR(S): Todd Crawford LOCAL PERSON(S) CONTACTED: Matthew McIver 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 lab analyzes samples for the Lower Cape Fear River Coalition and the City of Wilmington stormwater permits. The facility has all the equipment necessary to perform the analyses. The system for traceability of standard and reagent preparation is effective, thorough and easy to follow. Laboratory personnel communicate well with sample collectors and coordinate sample analyses effectively to manage workload and holding times. 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. The laboratory is reminded that any time changes are made to laboratory operations; the laboratory must update the Quality Assurance (QA)/Standard Operating Procedures (SOP) document(s). Any changes made in response to the Findings, Recommendations or Comments listed in this report must be incorporated to insure the method is being performed as stated, references to methods are accurate, and the QA and/or SOP document(s) is in agreement with approved practice and regulatory requirements. In some instances, the laboratory may need to create a SOP to document how new functions or policy will be implemented. Contracted analyses are performed by Environmental Chemists, Inc. (Certification #94). The requirements associated with Findings F and G have been implemented by our program since the last inspection. Page 2 #638 Aquatic Ecology Lab – UNCW Center for Marine Science III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation Recommendation: It is recommended that the analytical method reference be added to the Chlorophyll- a benchsheet. Recommendation: It is recommended that the following be added to the Chlorophyll-a report sheet. 1) Analysis date. 2) Units for the fluorometer reading. 3) Analytical method reference. A. Finding: An inconsistency was noted between the Chlorophyll-a Standard Operating Procedure (SOP) and laboratory practice as follows:  The SOP does not describe in detail how the method is performed, including: 1) Lighting conditions during the filtering and extraction processes. 2) State that samples must not be allowed to go to dryness during the filtering process. 3) Update the holding time to 3½ weeks. 4) Add the value from the fluorometer to the final calculation example. 5) Better define “dilution factor”. 6) Specify that the Laboratory Reagent Blank (LRB) is ground and extracted just like samples. 7) State the duplicate acceptance criterion. Requirement: 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. Ref: 15A NCAC 2H .0805 (a) (7). Please submit an updated SOP with the response to this report. B. Finding: The chlorophyll-a benchsheet is lacking units for temperature, standard concentrations, pipettor check volume weight, blank concentration, and fluorometer reading. Requirement: All laboratories must use printed laboratory bench worksheets that include a space to enter the signature or initials of the analyst, date of analyses, sample identification, volume of sample analyzed, value from the measurement system, factor and final value to be reported and each item must be recorded each time samples are analyzed. The date and time BOD and coliform samples are removed from the incubator must be included on the laboratory worksheet. Ref: 15A NCAC 2H .0805 (a) (7) (H). C. Finding: The chlorophyll-a benchsheet is lacking the final volume of the extraction solvent. This is considered pertinent information. Requirement: All analytical data pertinent to each certified analysis must be filed in an orderly manner so as to be readily available for inspection upon request. Ref: 15A NCAC 2H .0805 (a) (7) (A). D. Finding: Uncertified data is not documented as such on the benchsheets or final reports. Requirement: All uncertified data must be clearly documented as such on the benchsheet and on the final report. Ref: 15A NCAC 2H .0805 (e) (3). Page 3 #638 Aquatic Ecology Lab – UNCW Center for Marine Science Comment: The uncertified data was Stormwater turbidity and salinity data generated by the YSI Sonde probe and submitted to the City of Wilmington.. E. Finding: The freezer temperature log does not state the units of measure. Requirement: All laboratories must use printed laboratory bench worksheets that include a space to enter the signature or initials of the analyst, date of analyses, sample identification, volume of sample analyzed, value from the measurement system, factor and final value to be reported and each item must be recorded each time samples are analyzed. The date and time BOD and coliform samples are removed from the incubator must be included on the laboratory worksheet. Ref: 15A NCAC 2H .0805 (a) (7) (H). F. 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. G. Finding: The laboratory does not have a documented plan for proficiency testing procedures. Requirement: 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. Ref: 15A NCAC 2H .0805 (a) (7). Requirement: Laboratories must have a documented plan (this is usually detailed in the laboratory’s Quality Assurance Manual) of how they intend to cover the applicable program requirements for proficiency testing per their scope of accreditation. This plan shall cover any commercially available proficiency testing and any inter-laboratory organized studies, as applicable. The laboratory must also be able to explain when proficiency testing is not possible for certain parameters and provide a description of what the laboratory is doing in lieu of proficiency testing. This shall be detailed in the plan. The plan must also address the laboratory’s process for submission of proficiency testing results and related corrective action responses. Laboratory Standard Operating Procedures (SOPs) must address how low level samples will be analyzed, including concentration of the sample or adjustment of the normality of a titrant. These instructions shall be followed when the concentration of a PT sample falls below the range of their routine analytical method. Instructions shall also be included in the laboratory’s SOP for how high level samples will be analyzed, including preparation of multiple dilutions of the sample. These instructions will be followed when the concentration of a PT falls above the range of their routine analytical method. Ref: Proficiency Testing Requirements, February 20, 2012, Revision 1.2. pH - Standard Methods, 4500 H+ B-2000 H. Finding: The field sheet does not state the units of measure for pH (i.e., S.U.). Requirement: All laboratories must use printed laboratory bench worksheets that include a space to enter the signature or initials of the analyst, date of analyses, sample identif ication, volume of Page 4 #638 Aquatic Ecology Lab – UNCW Center for Marine Science sample analyzed, value from the measurement system, factor and final value to be reported and each item must be recorded each time samples are analyzed. The date and time BOD and coliform samples are removed from the incubator must be included on the laboratory worksheet. Ref: 15A NCAC 2H .0805 (a) (7) (H). I. Finding: A calibration check buffer is not analyzed prior to sample analysis. Requirement: For routine work, use a pH meter accurate and reproducible to 0.1 pH unit with a range of 0 to 14, equipped with a temperature compensation device. Follow all manufacturers’ recommendations for the calibration of the meter each analysis day. The meter must be calibrated with at least two buffers. In addition to the calibration standards, the meter must be verified with a third calibration standard. The calibration and check standard buffers must bracket the range of the samples being analyzed. Ref: NC WW/GW LC Approved Procedure for the Analysis of pH. Comment: The pH meter is calibrated at the lab and then the meter is carried to multiple sites for analyses. The check buffer was not being analyzed until after samples had been analyzed and the analyst had returned to the lab. The calibration must be verified prior to sample analysis. In addition, the calibration must be verified again after sample analyses to demonstrate that no calibration drift has occurred as result of moving from site to site. Conductivity - Standard Methods, 2510 B-1997 Comment: The Automatic temperature Compensator (ATC) was last checked on November 6, 2013, which is beyond the 12 month frequency requirement. The analyst stated that he was waiting until the inspection to ask a question about the ATC check procedure before completing the check. The NC WW/GW LC Approved Procedure for the Analysis of Specific Conductance (Conductivity) document states: The Automatic Temperature Compensator (ATC) must be verified annually (i.e., 12 months) at two temperatures by analyzing a standard or sample at 25°C (the temperature that conductivity values are compensated to) and a temperature(s) that brackets the temperature ranges of the environmental samples routinely 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 by email on 11/12/14. No further response is necessary for this finding. Temperature - Standard Methods, 2550 B-2000 Comment: The temperature sensor used for compliance monitoring was last checked on November 6, 2013, which is beyond the 12 month frequency requirement. The NC WW/GW LC Approved Procedure for the Analysis of Temperature document states: All thermometers and temperature measuring devices must be checked every 12 months against a National Institute of Standards and Technology (NIST) traceable thermometer. The process must be documented and proper corrections made to all compliance data. To check a thermometer or the temperature sensor of a meter, read the temperature of the thermometer/meter against a NIST traceable thermometer and record the two temperatures. The verification must be performed in the approximate range of the sample temperatures measured. The thermometer/meter readings must be less than or equal to 1ºC from the NIST traceable thermometer reading. The documentation must include the serial number of the NIST traceable thermometer that was used in the comparison. Also document any correction that applies on both the thermometer/meter and on a separate sheet to be filed. Demonstration of acceptable corrective action (i.e., documentation of acceptable temperature sensor checks) was received by email on 11/12/14. No further response is necessary for this finding. Page 5 #638 Aquatic Ecology Lab – UNCW Center for Marine Science Comment: The meters used to measure temperature were not labeled with the temperature correction factors. The NC WW/GW LC Approved Procedure for the Analysis of Temperature document states: All thermometers and temperature measuring devices must be checked every 12 months against a NIST traceable thermometer. The process must be documented and proper corrections made to all compliance data. The documentation must include the serial number of the NIST traceable thermometer that was used in the comparison. Also document any correction that applies on both the thermometer/meter and on a separate sheet to be filed. Notification of acceptable corrective action (i.e., a statement that the meters had been labeled with temperature correction factor) was received by email on 11/12/14. No further response is necessary for this finding. 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 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 25, 2014 Report reviewed by: Beth Swanson Date: December 1, 2014