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HomeMy WebLinkAboutNC0005321_Lab Inspection_20021028William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek, P.E: Director Division of Water Quality October 28, 2002 525 Mr. Bryan A. Laney Buckeye Lumberton Inc. P. O. Box 1305 Lumberton, NC 28359- SUBJECT: Laboratory Certification Maintenance Inspection Dear Mr. Laney: RECEIVED OCT 29 2002 DENR-FAYETfE►ALLE REGIONAL OFFICE Enclosed is a report for the inspection performed on September 27, 2002 by Mr. Frederick L. Bone. Where deficiencies are cited in this report, a response is required as well as for all lettered comments and/or recommendations. Withi thirty days of receipt, please supply this office with a written item for item description of how these deficiencies, comments and/or recommendations were corrected. We are seriously concerned about the CITED PREVIOUSLY deficiency(ies) found during the inspection. If the deficiencies cited in the enclosed report are not corrected, enforcement actions will 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. Please contact us at 919-733-3908 if you have questions or need additional information. Sincerely, 91aliW James W. Meyer Laboratory Section Enclosure cc: Frederick L. Bone Fayetteville Regional Office Laboratory Section (919) 733-3908 N. C. Division of Water Quality 1623 Mail Service Center Raleigh, NC 27699-1623 Fax: (919) 733-6241 Internet: dwglab.org Customer Service 1-800-623-7748 On -Site Inspection Report LABORATORY NAME: ADDRESS: CERTIFICATE NO: DATE OF INSPECTION: TYPE OF INSPECTION: EVALUATOR: LOCAL PERSON(S) CONTACTED: I. INTRODUCTION: - Buckeye Lumberton Inc. P.O. Box 1305 1000East Noir Street Lumberton, NC 28359 525 September 27, 2002 Maintenance Frederick L. Bone Bryan Laney 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 laboratory is spacious and well equipped. All facilities and equipment re well maintained. Records are well kept and most data looked good. Some further quality control procedures need to be implemented.• III. DEFICIENCIES, RECOMMENDATIONS, REQUIREMENTS, AND COMMENTS: General: 1. DEFICIENCY: The laboratory is not making the proper temperature coirrections on some the laboratory thermometers. CITED PREVIOUSLY Note: The laboratory is recording uncorrected temperature values on the temperature log books, : this causes the data to appear as if all of the temperature values are outside of the acceptable temperature range. Logbooks reviewed for the drying oven and BOD incubator contaied entries that were outside the acceptable temperature range for prolonged periods of time (> 30 days). The uncorrected temperature values make it appear that no corrective action is taken whenever operating temperatures are outside of the acceptable range, when in fact the temperatures were actually within the proper range when the temperature correction factor is considered. REQUIREMENT: All thermometers must meet National Institute of Standards and Technology (NIST) specifications for accuracy or be checked against a NIST traceable thermometer and proper corrections made. Ref: 15A NCAC 2H .0805 (a) (7) (o) A. COMMENT: Some of the daily logs and benchsheets used by the lablioratory do not contain all of the necessary labeling. information. Units of measure were not associated with some of the data values listed in the logbooks and benchsheets. CITED PREVIOUSLY Page 2 REQUIREMENT: The laboratory should review all of their benchsheets and log books to make sure that every entry is marked with the appropriate' unit of measure. Every number recorded on a benchsheet or logbook must have an appropriate unit assigned to it. B. COMMENT: The laboratory uses a humidity indicator rather than color indicating desiccant in the desiccator used .for total suspended solids samples. RECOMMENDATION: It is recommended that the laboratory include I color indicating desiccant as a backup to the humidity indicator that is currently being used in the desiccator. C. COMMENT: The laboratory does not have an adequate quality control; manual. Note: Please submit an updated QC plan to this office. REQUIREMENT: Analytical Quality control Program. 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. The quality control document shall be available for inspection by the State Laboratory. Ref. 15A NCAC 2H .0800 (a) (7). Temperature: D. COMMENT: The laboratory is reporting temperature readings directly from the Dissolved Oxygen meter. This meter has not been calibrated versus an NIST traceable thermometer. REQUIREMENT: All thermometers must meet National Institute of Standards and Technology (NIST) specifications for accuracy or be checked against a NIST traceable thermometer and proper corrections made. Ref. 15A NCAC 2H .0805 (a) (7) (o). Dissolved Oxygen: E. COMMENT: The laboratory documents the DO meter calibration on a separate form from the laboratory data benchsheets. RECOMMENDATION: It is recommended that the DO meter calibration information be kept on the same laboratory bench worksheet as the data to be reported. This will ensure that the calibration information for the DO meter is readily accessible. Y 2. DEFICIENCY: The laboratory does not meet the 15min. holding time for pH analysis. REQUIREMENT:. The maximum holding time for pH samples is 15 min.[ Ref: 40CFR. Ch table II. F. COMMENT: The laboratory does not use fresh buffer solutions daily The laboratory solutions from a large storage container into a smaller container and using this container indicated that after a period of approximately one week the buffer solutions were showing l .1(7-1-95) . p. 644 is pouring buffer repeatedly. Data deterioration. Page 3 RECOMMENDATION: It is strongly recommended that the laboratory pour up fresh pH buffer solutions each analysis day. These solutions should be discarded each day after use. This will help eliminate contamination and ensure that the laboratory produces accurate pH results. Total Suspended Solids: 3. DEFICIENCY: The laboratory is not analyzing a sample of sufficient size to yield 1.0 mg of residue on each filter. CITED PREVIOUSLY REQUIREMENT: The lab must filter enough sample to achieve >1.0 mg residue on the filter. Ref: EPA 600/4 - 79 -020, Revised Method 1983 Method 160.2 pg. 2-1. G. COMMENT: The laboratory does not record the time and date that the samples were placed into the oven and time and date that the samples were removed from the oven on the bench sheet for agreement with the drying time verification study. REQUIREMENT: The laboratory must record the time and date that the samples were placed into -the oven and time and date, that the samples were removed from the; oven on the bench sheet. Dry evaporated sample for at least 1 hour in an oven at 103 the 105°C, cool in desiccator to balance temperature, and weigh. Repeat cycle of drying, cooling, desiccation, antl weighing until a constant weight is obtained, or until weight change is less than 4% of previous weight or 0.5 mg, whichever is less. Ref: Standard Methods, 18th Edition 2540 D Total Suspended Solids at 103-105° C section (3) c p2-56. H. COMMENT: The laboratory could not produce all of the required quarterly performance evaluation data for the total suspended solids analysis. Data was filed in such manner as to make verification that the quarterly standards had been performed difficult. The laboratory was eventually able to produce most of the required information, but the organizational system for retrieving this data 'needs to be enhanced. RECOMMENDATION: It is strongly recommended that the laboratory fle all annual and quarterly quality control information in a single location. This will make verification for these types of performance evaluation results easier to locate during the audit process. Ammonia: 4. DEFICIENCY: The laboratory is not analyzing a second source QC standard daily for the ammonia analysis. REQUIREMENT: Analyze one known standard in addition to calibration standards each day samples are analyzed to document accuracy. This LCS (laboratory control standard) must be from a second source. For held curves for colorimetric methods, it must be analyzed after the! initial CCV (continuing calibration verification standard) is analyzed. It is recommended that this laboratory control standard, like the CCV, have a mid -range concentration and not vary by more than ± 10%. If it does, the analysis is out of control. The analysis must be terminated and the problem corrected. Ref: 15A NCAC 2H .0805 (a) (7) (B), (F), and Standard Methods, 18th Edition - Method 1020 B.3. Conductivity: I. COMMENT: The laboratory has not verified the temperature compensation of the conductivity meter verses an NIST traceable thermometer. Page 4 REQUIREMENT: All thermometers must meet National Institute of Standards and Technology (NIST) specifications for accuracy or be checked against a NIST traceable thermometer and proper corrections made. Ref. 15A NCAC 2H .0805 (a) (7) (o). J. COMMENT: The laboratory is experiencing ongoing difficulty with the conductivity analysis. Check standards are not recovering within acceptable tolerances of their true values after the meter has been calibrated. Laboratory has undertaken various means, to rectify this 'problem. Data reported while laboratory has been experiencing these problems has not been qualified. REQUIREMENT: When data does not meet all quality assurance measures,' the data must be qualified both on the laboratory bench worksheet and the DMR reporting form. IV. PAPER TRAIL INVESTIGATION: This consisted of comparing data reported on DMR's submitted to this Division :with the values obtained on laboratory bench worksheets. Data reviewed for the months of January, March, and July 2002 indicated no problems in proper data reporting. We are concerned with the deficiencies that were cited previously and not corrected. Failure to correct deficiencies and comments cited in this report will lead to enforcement action. V. CONCLUSIONS: Ref: 15A NCAC 2H .0807 (a) (1) and (14) Laboratory Decertification: A laboratory may be decertified for any or all parameters for up to one year for any or all of .the following infractions: (1) Failing to maintain the facilities, or records, or personnel, or equipment, or quality control program as set forth in the application, and these,Rules; or - (14) Failing to comply with any other terms, conditions, or requirements of this Section or of a Laboratory certification. Correcting the above deficiencies and comments should help them to produce quality data and meet certifica requirements. Please respond to all numbered Deficiencies and lettered Comments cited in this report. Report prepared by: Frederick L. Bone Date: September 30, 2002