HomeMy WebLinkAbout#5024_0513finalTS_2015_1
CDENR
North Carolina department of Environment and Natural Resources
Pat McCrory Donald R, van der Vaart
Governor Secretary
June 9, 2015
5024
Durafiber Technologies
Marty Stewart
338 Pea Ridge Road
New Hill, NC 27562-8951
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Stewart:
Enclosed is a report for the inspection performed on May 13, 2015 by Tonja Springer. 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 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.
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 us at (919)
733-3908.
Attachment
cc: Tonja Springer
Sincerely,
Dana Satterwhite, Environmental Program Supervisor
Division of Water Resources
Water Sciences Section
NC Wastewater/Groundwater Laboratory Certification Branch
1623 Mail Service Center, Raleigh, North Carolina 27699-1623
Location: 4405 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: 919-733-3908 i FAX: 919-733-6241
Internet: www.dwglab.org
An Equal Opportunity t Affirmative Action Employer
INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5024
Laboratory Name:
Durafiber Technologies
Inspection Type:
Field Maintenance
Inspector Name(s):
Tonia Springer
Inspection Date:
May 13, 2015
Date Report Completed:
June 4, 2015
Date Forwarded to Reviewer:
June 4, 2015
Reviewed by:
Nick Jones
Date Review Completed:
June 8, 2015
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:
June 8, 2015
Date Forwarded to Linda:
June 9 2015
Date Mailed:
June 9 2015
On -Site Inspection Report
LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
INTRODUCTION:
Durafiber Technologies
NC0001899
338 Pea Ridge Road
New Hill, NC 27562-8951
5024
May 13, 2015
Field Maintenance
Tonja Springer
Marty Stewart, Larry Murray and Earl Beal
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 laboratory was clean and well organized. The facility has all the equipment necessary to perform the
analyses.
PT samples for the 2015 proficiency testing calendar year have not yet been analyzed. The laboratory is
reminded that these results must be submitted to this office directly from the vendor by September 30,
2015.
Current quality assurance policies for Field Laboratories, an example benchsheet and approved
procedures for the analysis of the facility's currently certified parameters were provided at the time of
the inspection.
Contracted analyses are performed by Pace Analytical Services, Inc. - Huntersville (Certification #12) and
Pace Analytical Services, Inc. - Raleigh (Certification #67).
Per an email submitted on 5/22/2015, the laboratory's name changed from Performance Fibers, Inc. (PFI)
to Durafiber Technologies. An updated certificate with the laboratory's new name will be sent under
separate cover.
Per an email submitted on 5/22/2015, the laboratory requested to drop Conductivity. These analyses are
being performed by Pace Analytical Services, Inc. - Huntersville (Certification #12). An amended
certificate reflecting the deletion of Conductivity SM 2510 B-1997 (Aqueous) was mailed on June 8, 2015
with an effective date of May 22, 2015.
The requirement associated with Findings A, B and F have been implemented by our program since the
last inspection.
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#5024 Durafiber Technologies
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
Comment: Several instances of writing over a number as a means of error correction were observed.
Error corrections were not initialed or dated. The Quality Assurance Policies for Field Laboratories
document states: All documentation errors must be corrected by drawing a single line through the error
so that the original entry remains legible. Entries shall not be obliterated by erasures or markings. Wite-
Out®, correction tape or similar products designed to obliterate documentation are not to be used. Write
the correction adjacent to the error. The correction must be initialed by the responsible individual and the
date of change documented. All data and log entries must be written in indelible ink. Pencil entries are not
acceptable. Notification of acceptable corrective action (i.e., a statement that "All errors will be
corrected by drawing a single line thru it and initialed and dated." with an implementation date of
5/13/2015) was received by email on 5/22/2015. No further response is necessary for this finding.
A. Finding: The laboratory needed to increase the documentation of purchased 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. Consumable materials such as pH buffers and lots of pre -made
standards are included in this requirement. Ref: Quality Assurance Policies for Field
Laboratories. Please submit a copy of an updated completed benchsheet [or a log form
may be used] that includes the required traceability information and an implementation
date with the response to this report.
pH — Standard Methods, 4500 H+ B-2000
Comment: Numbers ending with a "T are not properly rounded when reporting pH results on the
Discharge Monitoring Reports (DMR). The laboratory is rounding up when the number preceding a 5 is
even. For example 7.45 is reported as 7.5 and not 7.4. Standard Methods, 1050 B-2006. (2) states:
Round off by dropping digits that are not significant. If the digit 6, 7, 8, or 9 is dropped, increase
preceding digit by one unit; if the digit 0, 1, 2, 3, or 4 is dropped, do not alter preceding digit. If the digit
5_is dropped, round off preceding digit to the nearest even number: thus 2.25 becomes 2.2 and 2.35
become 2.4. Notification of acceptable corrective action (i.e., a statement that "Our policy of rounding
moving forward will be the following: Even numbers are not rounded up when the next number is 5 or
below." "Odd numbers are rounded up for 5 and above." with an implementation date., of 5/13/2015)
was received by email on 5/22/2015. No further response is necessary for this finding.
pH — Standard Methods, 4500 H+ B-2000
Dissolved Oxygen — Standard Methods, 4500-0 G-2001
B. Finding: The laboratory benchsheets were lacking pertinent data: Instrument identification.
Requirement: The following must be documented in indelible ink whenever sample analysis is
performed: Instrument identification. Ref: NC WW/GW LC Approved Procedure for the Analysis
of pH and NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen. Please
submit a copy of an updated benchsheet that includes sample results with the response to
this report.
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#5024 Durafiber Technologies
Temperature — Standard Methods, 2560 B-2000
C. Finding: The temperature sensor on the pH meter used to obtain reported temperature values
has not been checked against a National Institute of Standards and Technology (NIST) traceable
thermometer within the past 12 months.
Requirement: Thermometers and temperature measuring devices, used to measure
temperature for compliance monitoring, must be checked every 12 months against a NIST
traceable thermometer. The thermometer/meter readings must be less than or equal to 1°C
from the NIST traceable thermometer reading. The documentation must include the serial
number of the NIST traceable thermometer that was used in the comparison. Document any
correction that applies on both the thermometer/meter and on a separate sheet to be filed. Ref:
NC WW/GW LC Approved Procedure for the Analysis of Temperature. Please submit a copy
of the NIST traceable calibration verification with the response to this report.
D. Finding: The laboratory is not documenting the following information for compliance Temperature
measurements: time of analysis and collection time.
Requirement: The following must be documented in indelible ink whenever sample analysis is
performed: Date and time of sample collection, date and time of sample analysis. Alternatively,
one time may be documented for collection and analysis with the notation that samples are
measured in situ or immediately at the sample site. Ref: NC WW/GW LC Approved Procedure for
the Analysis of Temperature. Please submit 2 months of updated completed benchsheets
that include sample results with the response to this report.
Comment: The reported temperature readings are recorded on the daily log and not the
benchsheet. The daily log does have a time documented, but it is not documented clearly to
indicate that it is time of analysis. Only "time" is documented. The method reference is not
documented on the daily log.
Comment: An updated benchsheet that merges the laboratory's daily log information and the
benchsheet was provided to the laboratory by email on 6/2/2015. There is space provided on this
benchsheet to document Temperature and the required supporting information.
Recommendation: It is recommended that the method reference be documented on the
benchsheet.
Dissolved Oxygen — Standard Methods, 4500-0 G-2001
E. Finding: The meter's calibration is being performed, but it is not documented each analysis
day.
Requirement: The following must be documented in indelible ink whenever sample analysis is
performed. Meter calibration and meter calibration time(s). Ref: NC WW/GW LC Approved
Procedure for Analysis of Dissolved Oxygen (DO).
Requirement: Instruments are to be calibrated according to the manufacturer's calibration
procedure prior to analysis of samples each day compliance monitoring is performed. Ref: NC
WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen (DO). Please submit 2
months of completed benchsheets with the response to this report.
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#5024 Durafiber Technologies
Requirement: The laboratory must document each time that a calibration is performed.
Calibration documentation must include the following, where applicable to the instrument used
and the type of calibration performed: elevation, temperature, barometric pressure (in mmHg),
salinity, slope, or %efficiency. Simply recording a final reading (in mg/L) for instruments that
auto calibrate (e.g., LDO sensors and Membrane Electrodes that AUTOCAL) is also
acceptable. Ref: NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen
(DO).
Comment: There is a column labelled as "Adjusted Air Calibration" on the benchsheet for DO but
nothing is being documented in the space below the header. The value obtained when the meter
is calibrated is the value that must be written in this space.
Proficiency Testing
F. Finding: The laboratory is not analyzing Proficiency Testing (PT) samples in the same manner
as environmental samples.
Requirement: All PT samples are to be analyzed and the results reported in a manner
consistent with the routine analysis and reporting requirements of compliance samples and any
other samples analyzed according to the requirements of 15A NCAC 2H .0800. Ref: Proficiency
Testing Requirements, February 20, 2012, Revision 1.2.
Comment: The laboratory was analyzing pH PT samples multiple times and reporting the first
sample result. Environmental samples are not analyzed and reported in this manner.
Comment: The laboratory's common practice was also to analyze a known standard along with
the PT sample as additional quality control. Since this is not performed with all environmental
samples, it is considered additional quality control. However, known samples are recommended
when analyzing remedial PT samples as part of the troubleshooting and corrective action process.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks, etc.)
and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North Carolina
Division of Water Resources. Data were reviewed for January and March, 2015. The following errors
were noted:
Date
Parameter
Location
Value on Benchsheet
Value on DMR
3/11 /2015
pH
Effluent
7.45 s.0
7.5 s.u*
3/23/2015
pH
Effluent
7.01 s.u.
7.3 s.u.
3/24/2015
pH
Effluent
7.35 s.u.
7.0 s.u.
* This appears to be a rounding error as noted in the corrected finding under the pH subheading
In order to avoid questions of legality, it is recommended that you contact the appropriate Regional
Office for guidance as to whether amended Discharge Monitoring Reports will be required. A copy of
this report will be made available to the Regional Office.
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#5024 Durafiber Technologies
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 and
include an implementation date for each corrective action.
Report prepared by: Tonja Springer Date: June 4, 2015
Report reviewed by: Nick Jones Date: June 8, 2015