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Home My WebLink About#5503_2012 INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5503 Laboratory Name: Corning Incorporated – Wilmington Facility Inspection Type: Field Maintenance Inspector Name(s): Todd Crawford Inspection Date: June 12, 2012 Date Report Completed: June 21, 2012 Date Forwarded to Reviewer: June 21, 2012 Reviewed by: Jason Smith Date Review Completed: June 22, 2012 Cover Letter to use: Insp. Initial X Insp. Reg. Insp. No Finding Insp. CP __ Corrected Unit Supervisor: Dana Satterwhite Date Received: June 25, 2012 Date Forwarded to Linda: June 28, 2012 Date Mailed: June 29, 2012 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Corning Incorporated – Wilmington Facility NPDES Permit #: NC0003794 ADDRESS: 310 N. College Road Wilmington, NC 28405 CERTIFICATE #: 5503 DATE OF INSPECTION: June 12, 2012 TYPE OF INSPECTION: Field Maintenance AUDITOR(S): Todd Crawford LOCAL PERSON(S) CONTACTED: Jennifer Adams and Eric Stroupe 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 laboratory was clean and well organized. The facility has all the equipment necessary to perform the analyses. The system for traceability of purchased materials and reagents needs to be increased; however, all other requested documentation was well organized and quickly made available. Proficiency Testing (PT) samples have been analyzed for all certified parameters for the 2011 proficiency testing calendar year and the graded results were 100% acceptable. PT samples for 2012 have been analyzed and submitted, but a final report has not yet been issued. Contracted analyses are performed by Environmental Analysts, Inc. (Certification #94). The requirements associated with Findings A, B and C are new policies that have been implemented by our program since the last inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation A. Finding: Proficiency Testing (PT) samples were not documented in the same manner as routine environmental samples. Requirement: 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. Ref: Quality Assurance Policies for Field Laboratories. Comment: Copies of PT documentation (submitted evaluation forms) were available. Page 2 #5503 Corning Incorporated – Wilmington Facility B. Finding: The laboratory needs to increase the documentation of purchased materials and 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. C. Finding: The preparation of 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. pH – Standard Methods, 19th Edition, 4500 H+ B D. Finding: Data values are reported on the Discharge Monitoring Report to 0.01 S.U. not 0.1 S.U. as required by the method. Requirement: A variance of ± 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). Temperature – Standard Methods, 19th Edition, 2550 B E. Finding: The pH meter, used to obtain reported temperature values, is not labeled with its temperature correction factor. Requirement: Document any correction that applies (even if zero) on both the meter and on a separate sheet to be filed. Ref: Technical Assistance for Field Analysis of Temperature. pH – Standard Methods, 19th Edition, 4500 H+ B Total Residual Chlorine – Standard Methods, 19th Edition, 4500 Cl G F. Finding: Meter calibration times are not documented for pH or Total Residual Chlorine. Requirement: Time of calibration must be documented whenever sample analysis is performed. Ref: Technical Assistance for Field Analysis of pH and Technical Assistance for Field Analysis of Total Residual Chlorine. Total Residual Chlorine – Standard Methods, 19th edition, 4500 Cl G G. Finding: Values below the established reporting limit of 0.2 mg/L are being reported on the DMR. Page 3 #5503 Corning Incorporated – Wilmington Facility Requirement: When performing the annual calibration curve verification, one of the standards must have a concentration equal to or below the lower reporting concentration for Total Residual Chlorine. Example: If the laboratory chooses to have a lower reporting limit of 0.2 mg/L for residual chlorine, you must analyze at least 0.2 mg/L or lower standard and report lower concentrations as < 0.2 mg/L or < the concentration of the chosen standard. Ref: Technical Assistance for Field Analysis of Total Residual Chlorine. 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 January, February and March, 2012. No transcription errors were noted, however, the Total Residual Chlorine column heading on the DMR was µg/L and data were being reported as mg/L. In order to avoid questions of legality, it is recommended that you contact the appropriate Regional Office for guidance as to whether an amended Discharge Monitoring 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 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: June 20, 2012 Report reviewed by: Jason Smith Date: June 22, 2012