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HomeMy WebLinkAbout#5477 - 10 - 2011 - FINALINSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5477 Laboratory Name: M.B. Industries Inc. Wastewater Treatment Plant Inspection Type: Field Maintenance Inspector Name(s): Jason Smith Inspection Date: October 6, 2011 Date Report Completed: October 17 2011 Date Forwarded to Reviewer: October 18, 2011 Reviewed bv: Jeffrey R. Adams Date Review Completed: October 19, 2011 Cover Letter to use: _ Insp. Initial X Insp. Reg. _ Insp. No Finding _ Insp. CP _Corrected Unit Supervisor: Gary Francies Date Received: 10/21/2011 Date Forwarded to Linda: 11/3/2011 Date Mailed: ; t 2 10 -fij'A NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director November 4, 2011 5477 Mr. Wade Sanders M.B. Industries, Inc. Wastewater Treatment Plant P.O. Box 1118 Rosman, NC 28772 SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Sanders: Dee Freeman Secretary Enclosed is a report for the inspection performed on October 6, 2011 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 me at 828-296-4677. Sincerely, Gary Francies Unit Supervisor Laboratory Section CC: Jason Smith Master File 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 NorthiCarolina Naturally An Equal Opportunity \ Affirmative Action Employer Customer Service: 1-877.623-6748 www.neGvaterquality.org LABORATORY NAME: M.B. Industries, Inc. Wastewater Treatment Plant NPDES PERMIT #: NC0000311 ADDRESS: P.O. Box 1118 Rosman, NC 28772 CERTIFICATE #: 5477 DATE OF INSPECTION: October 6, 2011 TYPE OF INSPECTION: Field Maintenance AUDITOR(S): Jason Smith LOCAL PERSON(S) CONTACTED: Wade Sanders and Conrad Strafford l I z k 1Z01BIil(i7p This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for the analysis of environmental samples. [t}: I -,I,1-: • t iti , The facility has all the equipment necessary to perform the analyses. Proficiency testing samples have been analyzed for all certified parameters for the 2011 proficiency testing calendar year and the graded results were 100% acceptable. The requirements associated with Findings A, B, C, and F are new policies that have been implemented by our program since the last inspection. A. Finding: Error corrections in data transcription are not dated when corrections are made.. 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. B. 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 Page 2 #5477 M.B. Industries, Inc. Wastewater Treatment Plant 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. C. Finding: Data that does not meet all quality control requirements is not qualified on the Discharge Monitoring Report (DMR). Requirement: When quality control (QC) failures occur, the laboratory must attempt to determine the source of the problem and must apply corrective action. Part of the corrective action is notification to the end user. If data qualifiers are used to qualify samples not meeting QC requirements, the data may not be useable for the intended purposes. It is the responsibility of the laboratory to provide the client or end -user of the data with sufficient information to determine the usability of the qualified data. Where applicable, a notation must be made on the DMR form, in the comment section or on a separate sheet attached to the DMR form, when any required sample quality control does not meet specified criteria and another sample cannot be obtained. Ref: Quality Assurance Policies for Field Laboratories. pH — Standard methods, 18th Edition, 4500 H+ B Temperature —Standard Methods, 18th Edition, 2550 B D. Finding: The traceable thermometer was past its calibration date. Requirement: NIST traceable thermometers used for temperature measurement must be recalibrated in accordance with the manufacturer's recalibration date. If no recalibration date is given, the NIST traceable thermometer must be recalibrated annually. Ref: Technical Assistance for Field Analysis of Temperature and Technical Assistance for Field Analysis of pH. Please submit a copy of the certification of the new traceable thermometer a copy of the temperature sensor check with the reply to this report. Comment: The traceable thermometer was due for calibration or replacement on October 1, 2010. E. Finding: The pH meter is not calibrated on the days when analyses are performed. Requirement: When only occasional pH measurements are made standardize instrument before each measurement. Ref: Standard Methods, 18th Edition, 4500 H+ B. (4) (a). Requirement: The meter must be calibrated prior to the analysis of samples. Ref: Technical Assistance for Field Analysis of pH. Comment: The laboratory began calibrating the instrument on Monday for process control samples, but not recalibrating on Wednesday, which is when NPDES samples are analyzed. This practice began when the primary analyst was out sick and was not corrected. F. Finding: Proficiency Testing (PT) samples are not analyzed and documented in the same manner as environmental samples. IN Page 3 #5477 M.B. Industries, Inc. Wastewater Treatment Plant Requirement: The analysis of performance testing (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: PT samples were analyzed multiple times and the results were not documented on daily benchsheets as environmental samples are documented. PAPER TRAIL INVESTIGATION: 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 M.B. Industries (NPDES permit #NC0000311) Outfall 001, Outfall 003, Upstream, and Downstream for January, March, and May, 2011. The following error was noted: Date Parameter Location Value on Contract Value on DMR Lab Report 1/4/2011 Chromium Effluent 0.13 mg/L 0.13 pg/L In order to avoid questions of legality, it is recommended that you contact the appropriate Regional Office for guidance as to whether an amended Discharge Monitoring Report will be required. A copy of this report will be forwarded to the Regional Office. Correcting the above -cited findings will help this lab to produce quality data and meet certification requirements. The inspectors 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 Report reviewed by: Jeffrey R. Adams Date: October 17, 2011 Date: October 19, 2011