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HomeMy WebLinkAbout#5081_09_2012_FINALINSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #. Laboratory Name: Inspection Type: Inspector Name(s): Inspection Date: Date Report Completed: Date Forwarded to Reviewer: Reviewed by: Date Review Completed: Cover Letter to use: Unit Supervisor: Date Received: Date Forwarded to Linda: Date Mailed: 5081 Tyson Foods Field Maintenance Jason Smith September 13, 2012 October 2, 2012 October 2 2012 Chet Whiting October 5, 2012 ❑ Insp. Initial ® Insp. Reg. ❑ Insp. No Finding ❑ Insp. CP ❑ Corrected Gary Francies 10/5/2012 10/9/2012 yc"Il a k NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Governor 5081 Mr. Mike Campbell Tyson Foods P.O. Box 158 Harmony, NC 28634 Charles Wakild, P. E. Director October 10, 2012 Dee Freeman Secretary Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Campbell: Enclosed is a report for the inspection performed on September by Jason Smith. 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. 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 828-296-4677. Sincerely, C4(� Gary Francies Certification Unit Supervisor Laboratory Section Enclosure cc: Master File Jason Smith DENR DWQ Laboratory Section NC Wastewater/Groundwater Laboratory Certification Branch 1623 Mail Service Center, Raleigh, North Carolina 27699-1623 Location: 4405 Reedy Creek Road. Raleigh, North Carolina 27607-6445 Phone: 919-733-3908 \ FAX: 919-733-6241 Internet: www.dwglab.org An Equal Opportunity \ Affirmative Action Employer ne NorthCarolina Natt(rallly LABORATORY NAME: NPDES PERMIT #: ADDRESS: CERTIFICATE #: DATE OF INSPECTION: TYPE OF INSPECTION: AUDITOR(S): LOCAL PERSON(S) CONTACTED: INTRODUCTION: Tyson Foods NC0005126 P.O. Box 158 Harmony, NC 28634 5081 September 13, 2012 Industrial Maintenance Jason Smith Mike Campbell 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. Current quality assurance policies for Field laboratories 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 Parr Laboratories (Certification #20). The requirements associated with Findings B, C, D, E, and F are new policies that have been implemented by our program since the last inspection. Ill. FINDINGS REQUIREMENTS COMMENTS AND RECOMMENDATIONS: Documentation A. Finding: Sample collection and analysis times need to be more clearly documented. Requirement: Data pertinent to each analysis must be maintained for five years. Certified Data must consist of date collected, time collected, samples site, sample collector, and sample analysis time. The field bench sheets must provide a space for the signature of the analyst, and proper units of measure for all analyses. Ref: 15A NCAC 2H .0805 (g) (1). Comment: Temperature, Dissolved Oxygen, and pH collection and analysis times are recorded under the heading title of "Time." These two times need to be more clearly labeled. Also, Dissolved Oxygen and Temperature are analyzed in stream, but it appears that they are collected and analyzed later when documented in this manner. Recommendation: Temperature and Dissolved Oxygen should be noted in the log book as analyzed in stream (insitu). Only one time would need to be documented in this situation. Page 2 #5081 Tyson Foods B. Finding: Error corrections are not dated when performed. Requirement: 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. Ref: Quality Assurance Policies for Field Laboratories. C. 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. Proficiency Testing D. Finding: The laboratory is not documenting Proficiency Testing (PT) sample analyses in the same manner as environmental samples. Requirement: All PT sample analyses must be recorded in the daily analysis records as for any environmental sample. This serves as the permanent laboratory record. Ref: Proficiency Testing Requirements, February 20, 2012, Revision 1.2. E. Finding: The preparation of 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. F. Finding: PT samples are not analyzed in the same manner as 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: Analyze PT samples on the same program, using the same procedure that is used for sample analysis. NPDES samples are analyzed using the Ultra Low Level TRC (pg/L) internal instrument standard curve; however, PT samples are analyzed using the Regular Level TRC (mg/L) internal instrument curve. Recommendation: Regular level PT samples may be diluted so that concentrations are within the verified (bracketed) curve range. Since the dilution process can introduce additional error, it is recommended that the facility analyze a low level TRC PT sample. These are currently available from many vendors. IV Page 3 #5081 Tyson Foods pH — Standard Methods, 4500 Hi' B G. Finding: Values were 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-2000, (6). Total Residual Chlorine — 4500 Cl G Comment: The laboratory was certified for Total Residual Chlorine (TRC) by Hach Method 8167 (HR) at the time of the inspection. This was determined to be an error since TRC is analyzed on the low level program of the meter. A corrected certificate attachment was issued to the laboratory on October 2, 2102 for Total Residual Chlorine by Standard methods 4500 CI G - 2000. Comment: The laboratory had, not assigned the gel standard a true value. The NC WW/GW LC Approved Procedure for Field Analysis of Total Residual Chlorine states: Purchased "Gel -type" or sealed liquid ampoule standards may be used for daily calibration verification only. These standards must be verified initially and every 12 months thereafter, with the standard curve. The assigned values will be used for the next twelve months, or until a new curve verification is performed. During the inspection, the true value was determined by reviewing data analyzed after the last standard curve verification was performed. It was acknowledged that the true value will be reassigned each year when the curve verification is performed. No further response is necessary for this finding. Temperature — Standard Methods 2550 B Comment: The temperature correction was not posted on the met Procedure for Field Analysis of Temperature states: Document any thermometer/meter and on a separate sheet to be filed. Laboratory correction on the meter during the inspection and understood that thi further response is necessary for this finding. mete PAPER TRAIL INVESTIGATION: s The NC WW/GW LC Approved correction that applies on both the personnel posted the temperature is to be performed every year. No 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 Tyson Foods (NPDES permit #NC0005126) for January, February, and March, 2012. No transcription errors were detected. 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 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: Jason Smith Date: October 2, 2012 Report reviewed by: Chet Whiting Date: October 5, 2012