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INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #: 245
Laboratory Name: Perdue, Inc.
Inspection Type: Industrial Maintenance
Inspector Name(s): Todd Crawford
Inspection Date: June 30, 2009
Date Report Completed: July 6, 2009
Date Forwarded to Reviewer: July 6, 2009
Reviewed by: Tonja Springer
Date Review Completed: July 14, 2009
Cover Letter to use: Insp. Initial X Insp. Reg. Insp. No Finding __ Insp. CP
Unit Supervisor: Dana Satterwhite
Date Received: July 14, 2009
Date Forwarded to Alberta: July 14, 2009
Date Mailed:
_____________________________________________________________________
On-Site Inspection Report
LABORATORY NAME: Perdue, Inc
ADDRESS: P.O. Box 460
Lewiston, NC 27849
NPDES PERMIT # NC0028835
CERTIFICATE #: 245
DATE OF INSPECTION: June 30, 2009
TYPE OF INSPECTION: Industrial Maintenance
AUDITOR(S): Todd Crawford and Tony Hatcher
LOCAL PERSON(S) CONTACTED: Tina Rawls
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 lab was clean and well organized. All equipment appeared well maintained.
Policy statements and guidance documents for consumables testing and matrix spiking were
provided during the inspection.
Finding C is a new requirement since the last inspection.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
A. Finding: The edition of Standard Methods referenced on many of the benchsheets is
wrong.
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).
Recommendation: Review all benchsheets for method reference accuracy.
B. Finding: Values in gram units are being recorded in a column titled “Mg Increase in
Weight” on both the Total Solids and Total Dissolved Solids benchsheets.
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
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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).
Recommendation: Review all benchsheets for measurement unit accuracy.
Temperature Sensing Devices
C. Finding: The temperature sensor on the pH meter has not been checked against a
NIST thermometer.
Requirement: The laboratory shall maintain records of established correction factors
to correct all measurements. The documentation must include the serial number of
the NIST certified thermometer or NIST traceable thermometer that was used in the
comparison, the date the calibration was checked, and initials of analyst. Document
any correction that applies (even if zero, e.g., 0.0) on both the thermometer/meter and
on a separate sheet to be filed. Ref: North Carolina Wastewater/Groundwater
Laboratory Certification Policy.
Coliform Fecal - Standard Methods, 19th Edition, 9222 D (MF)
Comment: Samples in the water bath at the time of the inspection were barely below the
surface of the water. Plates must be anchored in the waterbath in such a way that the water
can circulate around the plates creating a uniform temperature environment.
D. Finding: Consumable material testing is only being performed on the sample pads.
Requirement: W hen a new lot of culture medium, membrane filters, or a new source
of reagent-grade water is to be used, or at annual testing of water, make comparison
tests of the current lot in use (reference lot) against the new lot (test lot). Ref:
Standard Methods, 19th Edition, 9020 B. (3) (d).
Ammonia Nitrogen – Standard Methods, 18th Edition, 4500-NH3 E
E. Finding: Matrix spikes are not being analyzed.
Requirement: Unless the referenced method states a greater frequency, include one
Matrix Spike (MS) with each sample set (batch – 20 or fewer samples) or on a 5%
basis. Prepare the MS from a reference source different from that used for calibration
unless otherwise stated in the method. Laboratories analyzing less than 20 samples
per month must analyze at least one MS each month samples are analyzed. If MS
results are out of control, the results must be qualified or the laboratory must take
corrective action to rectify the effect, use another method, or employ the method of
standard additions. Refer to the method of choice for specific acceptance criteria for
the MS until the laboratory develops or adopts statistically valid, laboratory-specific
performance criteria for accuracy. Ref: North Carolina Wastewater/Groundwater
Laboratory Policy.
Total Kjeldahl Nitrogen – Standard Methods, 18th Edition, 4500-NH3 E
Comment: Samples are currently being sent to a contract lab for analysis. If this method is
performed in-house, please remember that the Matrix Spike policy will apply.
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Oil & Grease – EPA Method 1664 Rev. A
F. Finding: The drying cycle for each sample is not being repeated.
Requirement: Repeat the cycle of drying, cooling, desiccating, and weighing until the
weight loss is less than 4% of the previous weight or less than 0.5 mg, whichever is
less. Ref: EPA Method 1664 A. Section 11.4.4.
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
Quality. Data were reviewed for NPDES permit # NC0028835 for April, 2009. The following
error was noted:
BOD data for 04/29/09 was qualified on the DMR for a failing GGA standard. The
failing GGA standard did not affect samples collected on 04/29/09. The samples
affected by the failing GGA standard were collected on 04/23/09 and 04/24/09.
A Total Residual Chlorine standard analyzed on 04/23/09 did not pass. The
corresponding data was not qualified on the DMR.
In order to avoid questions of legality, it is recommended that you contact the appropriate
Regional Office for guidance as to whether an amended DMR report will be required. A copy
of this report will be forwarded to the Regional Office.
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: July 6, 2009
Report reviewed by: Tonja Springer Date: July 14, 2009