HomeMy WebLinkAbout#412_ 2011
INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #: 412
Laboratory Name: Smithfield Packing Company WWTP Lab
Inspection Type: Industrial Maintenance
Inspector Name(s): Tonja Springer, Gary Francies, and David Livingston
Inspection Date: June 21, 2011
Date Report Completed: July 13, 2011
Date Forwarded to Reviewer: July 15, 2011
Reviewed by: Jason Smith
Date Review Completed: July 22, 2011
Cover Letter to use: Insp. Initial __Insp. Reg. Insp. No Finding Insp. CP X Corrected
Unit Supervisor: Dana Satterwhite
Date Received: July 26, 2011
Date Forwarded to Linda: August 1, 2011
Date Mailed: August 1, 2011
_____________________________________________________________________
On-Site Inspection Report
LABORATORY NAME: Smithfield Packing Company WWTP Lab
NPDES PERMIT #: NC0078344
ADDRESS: P.O. Box 189
Tar Heel, NC 28392
CERTIFICATE #: 412
DATE OF INSPECTION: June 21, 2011
TYPE OF INSPECTION: Industrial Maintenance
AUDITOR(S): Tonja Springer, Gary Francies, David Livingston
LOCAL PERSON(S) CONTACTED: Xiaolin Chen
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 inspectors would like to commend the laboratory for staying current with changes in laboratory
certification program requirements by visiting the NC Wastewater/Groundwater Laboratory Certification
website and proactively implementing new requirements (such as reporting limit changes for Total
Suspended Solids and matrix spiking) between inspections.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
General Laboratory
Comment: Uncertified data (i.e., process control data) was documented with the certified data and not
clearly identified. The North Carolina Administrative Code, 15A NCAC 2H .0805 (e) (3) states: All
uncertified data must be clearly documented as such on the benchsheet and on the final report.
Demonstration of acceptable corrective action (i.e., an updated benchsheet) was received by electronic
mail on 6/29/2011. No further response is necessary for this finding.
Comment: The autoclave maximum pressure and the material autoclaved are not being documented on
the autoclave logbook. The North Carolina Administrative Code, 15A NCAC 2H .0805 (a) (7) (J) states:
Each day an incubator, oven, water bath or refrigerator is used, the temperature must be checked,
recorded, and initialed. During each use the autoclave maximum temperature and pressure must be
checked, recorded, and initialed. Demonstration of acceptable corrective action (i.e., an updated
logbook sheet with spaces added to record maximum pressure and the material autoclaved) was
received by electronic mail on 6/29/2011. No further response is necessary for this finding.
Page 2
#412 Smithfield Packing Company WWTP Lab
Biochemical Oxygen Demand – Standard Methods, 19th Edition, 5210 B
Comment: The initial pH of samples is not being documented. The North Carolina Administrative
Code, 15A NCAC 2H .0805 (a) (7) states: Each laboratory shall develop and maintain a document
outlining the analytical quality control practices used for the parameters included in their certification.
Supporting records shall be maintained as evidence that these practices are being effectively carried out.
Demonstration of acceptable corrective action (i.e., an updated copy of the page in the Standard
Operating Procedures (SOP)) was received by electronic mail on 6/29/2011. No further response is
necessary for this finding.
Comment: Total residual chlorine strips are being used to test for chlorine. North Carolina
Wastewater/Groundwater Laboratory Certification Policy states: It is acceptable to screen samples
with DPD powder for the presence of Total Residual Chlorine (use pillows appropriate for the volume of
sample tested). Generally total residual chlorine test strips are not adequate; however, these may be
used for samples where interference with DPD precludes their use. Notification of acceptable
corrective action (i.e., the laboratory stated they will be using the DPD method to check the final
effluent for total residual) chlorine was received by electronic mail on 6/29/2011. No further response
is necessary for this finding.
Comment: The Dissolved Oxygen (DO) meter is not checked for drift at the end of the analytical series.
North Carolina Wastewater/Groundwater Laboratory Certification Policy based upon Standard
Methods, 21st Edition, 5210 B. (5) (g) states: If the membrane electrode method is used, take care to
eliminate drift in calibration between initial and final DO readings. Demonstration of acceptable corrective
action (i.e., an updated benchsheet along with a statement regarding a drift check had been added at
end of each test) was received by electronic mail on 6/29/2011. No further response is necessary
for this finding.
Fecal Coliform – Standard Methods, 19th Edition, 9222 D (MF)
Comment: The laboratory needed to increase the traceability of the consumable materials to the
analytical batches. North Carolina Wastewater/Groundwater Laboratory Certification Policy 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 (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, lots of pre-made standards and/or media, solids and bacteria filters, etc. are
included in this requirement. Notification of acceptable corrective action (i.e., the laboratory stated, for
traceability purposes during consumable studies for fecal, they will be tracking the lot numbers of
consumable items used for final effluent analysis) was received by electronic mail on 6/29/2011. No
further response is necessary for this finding.
Comment: The chlorine removal check is not being documented. The North Carolina Administrative
Code, 15A NCAC 2H .0805 (a) (7) (M) states: A record of date collected, time collected, sample
collector, and the use of proper preservatives must be maintained. Demonstration of acceptable
corrective action (i.e., an updated benchsheet along with a statement that the chlorine removal check is
being documented) was received by electronic mail on 6/29/2011. No further response is necessary
for this finding.
Page 3
#412 Smithfield Packing Company WWTP Lab
Comment: Duplicate acceptance criteria are not documented in the SOP. The North Carolina
Administrative Code, 15A NCAC 2H .0805 (a) (7) states: Each laboratory shall develop and maintain a
document outlining the analytical quality control practices used for the parameters included in their
certification. Supporting records shall be maintained as evidence that these practices are being effectively
carried out. Demonstration of acceptable corrective action (i.e., an updated copy of the page in the
SOP which describes a two tiered system for establishing duplicate criteria) was received by electronic
mail on 6/29/2011. No further response is necessary for this finding.
Comment: Ultraviolet sterilization lamps are not tested quarterly. Standard Methods, 19th Edition,
9020 B. (2) (m) states: Disconnect unit monthly and clean lamps by wiping with a soft cloth moistened
with ethanol. Test lamps quarterly with UV light meter and replace if they emit less than 70% of initial
output or if plate count agar spread plates containing 200 to 250 microorganisms, exposed to the light
for 2 min, do not show a count reduction of 99%. Notification of acceptable corrective action (i.e., a
statement regarding the UV sterilizer will no longer be used, instead the lab will use the autoclave for
disinfection of all fecal test apparatus) was received on 6/29/2011 by electronic mail. No further
response is necessary for this finding.
Comment: Coliform density was not calculated correctly on a sample that had not yet been reported.
The sample was analyzed on 6/3/2011. The calculated result was 57 colonies per 100 mL. From the
Fecal Coliform Reporting document, the lab was using Rule #2 (b) which states: Total the counts of all
filters and report as number per 100 mL. In this instance, the laboratory should have used Rule #1
which states: If more than one filter has a count in the acceptable range, calculate the values in
counts/100 mL and average. This was corrected at the time of the inspection. The corrected result was
62.5 colonies per 100 mL. No further response is necessary for this finding.
Recommendation: It was recommended that the lab use glass, class A pipettes for measuring
sample volumes of 10 mL or less instead of the graduated cylinders. An electronic mail was received
on 6/29/2011 indicating that the laboratory will begin using pipettes for sample volumes 10 mL or less.
Recommendation: It was recommended that the lab add columns to the benchsheet for the calculated
results and final reported results. An updated benchsheet with these recommendations implemented
was received by electronic mail on 6/29/2011.
Total Suspended Residue – Standard Methods, 19th Edition, 2540 D
Comment: Filters are not weighed to a constant weight after initial washing nor is a dry filter blank
analyzed with each set of samples. North Carolina Wastewater/Groundwater Laboratory Certification
Policy, based upon Standard Methods, 20th Edition, 2540 D. (3) (a) states: If pre-prepared filters are
not used, the method requires that filters must be weighed to a constant weight after washing. In lieu of
this process, it is acceptable to analyze a single daily dry filter blank (i.e., no additional rinsing during
the analysis). The acceptance criterion for the blank is a weight change of less than 4% of the filter’s
initial weight or 0.5 mg, whichever is less. This requirement is a new policy that has been implemented
by our program since the last inspection. Demonstration of acceptable corrective action (i.e., an
updated benchsheet indicating that a dry blank is being analyzed) was received by electroinc mail on
6/29/2011. No further response is necessary for this finding.
Settleable Residue – Standard Methods, 19th Edition, 2540 F
Comment: The sample volume is not documented. The North Carolina Administrative Code, 15A
NCAC 2H .0805 (a) (7) (H) states: All laboratories must use printed laboratory bench worksheets that
include a space to enter the signature or initials of the analyst, date of analyses, sample identification,
volume of sample analyzed, value from the measurement system, factor and final value to be reported
and each must be recorded each time samples are analyzed. Demonstration of acceptable corrective
Page 4
#412 Smithfield Packing Company WWTP Lab
action (i.e., an updated benchsheet) was received by electronic mail on 6/29/2011. No further
response is necessary for this finding.
Total Kjeldahl Nitrogen – Standard Methods, 19th Edition, 4500 NH3 D
Comment: Laboratory reagent blanks exceed 50% of the reporting limit. North Carolina
Wastewater/Groundwater Laboratory Certification Policy states: For analyses requiring a calibration
curve, the concentration of method and reagent blanks must not exceed 50% of the reporting limit,
unless otherwise specified by the reference method. This requirement is a new policy that has been
implemented by our program since the last inspection. Demonstration of acceptable corrective action
(i.e., an updated benchsheet) was received by electronic mail on 6/29/2011. No further response is
necessary for this finding.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing laboratory benchsheets and contract lab reports to Discharge
Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data were
reviewed for January and April 2011. No transcription errors were detected. The facility appears to be
doing a good job of accurately transcribing data.
V. CONCLUSIONS:
All findings noted during this inspection were adequately addressed prior to the completion of this
report. The inspector would like to thank the staff for its assistance during the inspection and data
review process. No response is required.
Report prepared by: Tonja Springer Date: July 13, 2011
Report reviewed by: Jason Smith Date: July 22, 2011