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HomeMy WebLinkAbout#5030_2019_1106_AO_FINALLaboratory Cert. : 5030 Laboratory Name: Ingersoll-Rand Inspection Type: Field Industrial Maintenance Inspector Name(s): Anna Ostendorff Inspection Date: 11/6/2019 Date Forwarded for Initial Review: 11/18/2019 Initial Review by: Thomas Halvosa Date Initial Review Completed: 11/19/2019 Cover Letter to use: ❑ Insp. Initial ® Insp. Reg ❑Insp. No Finding ❑Insp. CP ❑Corrected ❑Insp. Reg. Delay Unit Supervisor/Chemist III: Beth Swanson Date Received: 11/19/2019 Date Forwarded to Admin.: 11/20/2019 Date Mailed: 11/20/2019 Special Mailing Instructions: ROY COOPER ICHA L S. REGAN Serc'wy LINDA. CULt EPEE 5030 Mr. William Minchew Ingersoll-Rand P.O. Box 7426 Rocky Mount, NC 27804 NORTH CFI, O',LlNA Environmental QuWily November 20, 2019 Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Minchew: Enclosed is a report for the inspection performed on November 6, 2019 by Anna Ostendorff. Where Finding(s) are cited in this report, a response is required. Within thirty days of receipt, please supply this office with a written item for item description of how these Finding(s) were corrected. Please describe the steps taken to prevent recurrence and include an implementation date for each corrective action. If the Finding(s) cited in the enclosed report are not corrected, enforcement actions may be recommended. For Certification maintenance, your laboratory must continue to carry out the requirements set forth in 15A NCAC 2H .0800. A copy of the laboratory's Certified Parameter List at the time of the audit is attached. This list will reflect any changes made during the audit. Copies of the checklists completed during the inspection may be requested from this office. Thank you for your cooperation during the inspection. If you wish to obtain an electronic copy of this report by email or if you have questions or need additional information, please contact me at (919) 733-3908 Ext. 259. Sincerely, rr Beth Swanson Technical Assistance & Compliance Specialist Division of Water Resources Attachment cc: Anna Ostendorff, Dana Satterwhite North Carolina Department of Environmental Quality I Division of Water Resources Io NA-1 c,,.,,1.,., n_­, I o., ilk nL.,-r b. n.. -N.,_ 07cnn 4c7o CERTIFICATE #: AUDITOR(S): Ingersoll-Rand NC0079227 213 Red Iron Road Rocky Mount, NC 27804 5030 November 6, 2019 Field Industrial Maintenance Anna Ostendorff William Minchew I. INTRODUCTION: Groundwater This laboratory was inspected by a representative Laboratory Certification (NC WW/GW LC) pog mftohverify is coe North mpliance ante with theolina requirements of 15A NCAC 2H .0800 for the analysis of environmental samples. II. GENERAL COMMENTS: The facility is neat and well organized and has easy all tothe followequipment concise. Records are well analyses. Benchsheets are well rm the designed, Y with updates organized and easy to retrieve. The laboratory is prepared t p mpleoactlment the ve in pew requirements as and changes required by thisg defined in the revised Rules. The laboratory supervisor was forthcoming and seemed eager to adopt the necessary changes. All required Proficiency Testing (PT) Sampleshavebeen analyzed for the 2019 PT Calendar Year /o and the graded results were 100 acceptable. Contracted analyses are performed by Pace Analytical Services, LLC — Raleigh NC (Certification # 67) and ETT Environmental, Inc (Certification # 686). III. FINDINGS REQUIREMENTS COMMENTS AND RECOMMENDATIONS: Documentation A. Finding: The laboratory needs to increase the traceability documentation of purchased materials and reagents. This is considered pertinent data. Page 2 #5030 Ingersoll-Rand Requirement: Chemical containers shall be dated when received and when opened. Reagent containers shall be dated, identified, and initialed when prepared. Chemicals and reagents exceeding the expiration date shall not be used. Chemicals and reagents shall be assigned expiration dates by the laboratory if not given by the manufacturer. If the laboratory is unable to determine an expiration date for a chemical or reagent, a one-year time period from the date of receipt shall be the expiration date unless degradation is observed prior to this date. The laboratory shall have a documented system of traceability for all chemicals, reagents, standards, and consumables. Ref: 15A NCAC 2H .0805 (g) (7). 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 and lots of pre -made standards and/or media solids and bacteria filters, etc. are included in this requirement. Ref: NC WW/GW LC Policy. Comment: Dates received and opened were written on the pH buffer bottles. While this can provide a traceability link to analyses by looking at the dates that the chemicals were in use, that link is lost once the bottles are discarded. A log sheet that may be used for documenting traceability was provided by email November 8, 2019. B. Finding: The units of measure (i.e., Standard Units or S.U.) are not documented on the benchsheets. Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data shall be traceable to the associated sample analyses and shall consist of: the proper units of measure. Each item shall be recorded each time samples are analyzed. Ref: 15 NCAC 2H .0805 (g) (2) (Q. Reporting C. Finding: The laboratory does not report results of all tests on the characteristics of the effluent. Requirement: The results of all tests on the characteristics of the effluent, including but not limited to NPDES permit monitoring requirements, shall be reported on the monthly report forms. Ref: 15A NCAC 213.0506 (b) (3) (J). Comment: The permit does not require Temperature monitoring. The laboratory is voluntarily measuring and documenting Temperature of the Effluent when analyzing the pH compliance sample. The laboratory may discontinue analyzing Temperature or continue analyzing Temperature and report the results in the comment section on the DMR. pH — Standard Methods, 4500 H+ B-2011 (Aqueous) Page 3 #5030 Ingersoll-Rand D. Finding: Values are 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-2011. (6). Comment: Per PT Vendor instructions, the PT Sample results should be reported to two decimal places. Recommendation: The laboratory currently reports pH sample results to two decimal places. It is recommended that the laboratory continue to measure and document sample results on the benchsheet to two decimal places, and to round to the nearest 0.1 S.U. when reporting results on the DMR. Temperature — Standard Methods, 2550 B-2010 (Aqueous) Recommendation: It is recommended that Temperature results be reported on the DMR in whole numbers. E. Finding: The annual temperature -measuring device check procedure is not performed correctly. Requirement: To check a compliance temperature -measuring device, compare readings at two temperatures that bracket the range of compliance samples routinely analyzed against a National Institute of Standards and Technology (NIST) traceable temperature - measuring device and record all four readings. The readings from both devices must agree within 0.5 °C. Ref: NC WW/GW LC Approved Procedure for the Analysis of Temperature. Comment: The temperature -sensing device was verified at one temperature. The laboratory was sending the pH meter used to measure temperature to a calibration company out of state who is unfamiliar with NC WW/GW LC requirements. IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks, etc.) and contract lab reports to DMRs submitted to the North Carolina Division of Water Resources. Data were reviewed for Ingersoll-Rand (NPDES permit # NC0079227) for April, August and September 2019. No transcription errors were observed. The facility appears to be doing a good job of accurately transcribing data. V. CONCLUSIONS: Correcting the above -cited Findings and implementing the Recommendations will help this laboratory to produce quality data and meet Certification requirements. The inspector would like to thank the staff for their assistance during the inspection and data review process. Please respond to all Findings and include supporting documentation, implementation dates and steps taken to prevent recurrence for each corrective action. Report prepared by: Anna Ostendorff Date: November 18, 2019 Report reviewed by: Tom Halvosa Date: November 19, 2019 CD \ j 2 w E k k ) 2 C) ) \ 7 \ / \ j \ j } ) / � / § \ 2 ( (L 2 § \ � j § \ co \ z $ / _ / 0 z _ ) / \ { Q = _ 2w a) CO ) ? / ƒ 8 c Cr 2 § W o E os f \ co ° § _ 2 z / \ / Lo \ ) } k § £ U) (o