#5320_0506finalTS_2015_

L
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory Donald R. van der Vaart
Governor Secretary
June 8, 2015
5320
'Chris Graham and Rolland Waters
Pilkington North America, Inc.
13121 South Rocky Ford Road
Laurinburg, NC 28353
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Graham and Mr. Waters:
Enclosed is a report for the inspection performed on May 6, 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.
Sincerely,
Dana Satterwhite, Environmental Program Supervisor
Division of Water Resources
'.Attachment
cc: Tonja Springer
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: [phone] t FAX: [phone]
Internet: www.dwgiab.orq
An Equal Opportunity 1 A`firmahe Action Employer

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5320
Laboratory Name:
Pilkinqton North America, Inc.
Inspection Type:
Field Maintenance
Inspector Name(s):
Tonia Springer
Inspection Date:
May 6, 2015
Date Report Completed:
May 29, 2015
Date Forwarded to Reviewer:
May 29, 2015
Reviewed by:
Jason Smith
Date Review Completed:
June 2 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 2, 2015
Date Forwarded to Linda:
June 8, 2015
Date Mailed:
June 8, 2015

On -Site Inspection Report
LABORATORY NAME:
ADDRESS:
NPDES PERMIT #
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
I. INTRODUCTION:
Pilkington North America, Inc.
13121 South Rocky Ford Rd.
Laurinburg, NC 28353
NCO049514
5320
May 6, 2015
Field Maintenance
Tonja Springer
Chris Graham and Rolland Waters
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 facility has all the equipment necessary to perform the analyses.
Proficiency Testing (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.
Contracted analyses are performed by Environmental Science Corporation dba: ESC Lab Sciences.
(Certification #375), Element One, Inc. (Certification #604), and Leith Creek WWTP Lab (Certification
#133) performs Total Residual Chlorine analyses at no charge.
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.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
Comment: The benchsheet for pH was lacking the following required information:
• Sample site including facility name and location, ID, etc.
• Instrument identification.
• Meter calibration time
• True value for the check standard buffer
• Value obtained for the check standard buffer

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#5320 Pilkington North America, Inc.
• Collection time and date
Analyst's initials
Time of analysis (need to be clearly documented)
The NC WW/GW LC Approved Procedure for the Analysis of pH document states: The following must be
documented in indelible ink whenever sample analysis is performed:
• Sample site including facility name and location, ID, etc.
• ♦Instrument identification.
• ♦Meter calibration and meter calibration time(s)
• True values for the check standard buffer
• Value obtained for the check standard buffer (verification of ± 0.1 S.U.)
• Date and time of sample collection
• Collector's/analyst's name and initials
• Date and time of sample analysis to verify the 15 minute holding time is met. Alternatively, one
may be documented for collection and analysis with the notation that samples are measured in
situ or immediately at the sample site.
The requirements noted with (♦) are new policies that have been implemented by our program since the
last inspection. Demonstration of acceptable corrective action (i.e., an updated completed benchsheet
which includes all the required information with an implementation date of May 15, 2015) was received by
email on 5/28/2015. No further response is necessary for this finding.
Comment: The laboratory needs to increase the documentation of purchased reagents. The Quality
Assurance Policies for Field Laboratories document states: 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. This is a new policy that has
been implemented by our program since the last inspection. Demonstration of acceptable corrective
action (i.e., an updated completed benchsheet which includes traceability information with an
implementation date of May 15, 2015) was received by email on 5/28/2015. No further response is
necessary for this finding.
Comment: Error corrections were not performed properly. 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 correction action (i.e., a statement that, From
May 9, 2015 and forward, we shall make error corrections with just one line drawn thru the erroneous
data. The individual making the correction shall annotate the error with their initials and date.) was
received by email on 05/28/2015. No further response is necessary for this finding.
PH — Standard Methods, 4500 H+ B-2000
Comment: The laboratory was not including units of measure for pH on laboratory benchsheets. The
North Carolina Administrative Code, 15A NCAC 2H .0805 (g) (1) states: Data pertinent to each analysis
must be maintained for five years. Certified Data must consist of date collected, time collected, sample
site, sample collector, and sample analysis time. The field benchsheets must provide a space for the
signature or initials of the analyst, and proper units of measure for all analyses. Demonstration of
acceptable corrective action (i.e., an updated completed benchsheet which includes units of measure with

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#5320 Pilkington North America, Inc.
an implementation date of May 15, 2015) was received by email on 5/28/2015. No further response is
necessary for this finding.
Comment: The Automatic Temperature Compensator (ATC) verification of the pH meter is no longer
required.
A. Finding: Sample results are reported to two decimal places.
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-2000, (6).
Temperature — Standard Methods, 2550 B-2000
Comment: Temperature was being documented directly on the Discharge Monitoring Report (DMR) and
the Chain of Custody and not on a benchsheet; therefore pertinent information (i.e., the signature or
initials of the analyst and proper units of measure) was not being documented. The North Carolina
Administrative Code, 15A NCAC 2H .0805 (g) (1) states: Data pertinent to each analysis must be
maintained for five years. Certified Data must consist of date collected, time collected, sample site,
sample collector, and sample analysis time. The field benchsheets must provide a space for the signature
or initials of the analyst, and proper units of measure for all analyses. Demonstration of acceptable
corrective action (i.e., an updated completed benchsheet including Temperature with all the pertinent
information, with an implementation date of May 15, 2015) was received by email on 5/28/2015. No
further response is necessary for this finding.
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 permit #NC0049514 for January, February, and
March, 2015. No transcription errors were detected. The facility appears to be doing a good job of
accurately transcribing data.
V. CONCLUSIONS:
Correcting the above -cited finding 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 the finding and include an implementation date for the
corrective action.
Report prepared by: Tonja Springer Date: May 29, 2015
Report reviewed by: Jason Smith Date: June 2, 2015