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Home My WebLink About#5320_2021_0624_TS_FINAL July 13, 2021 5320 Mr. Chris Graham Pilkington North America Inc. 13121 South Rocky Ford Rd. Laurinburg, NC 28353- Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection D ear Mr. Graham: Enclosed is a report for the inspection performed on June 24, 2021 by Tonja Springer. Where Finding(s) are cited in this report, a response is required. Within thirty days , please supply this office with a written item for item description of how these Finding(s) were corrected. Please describe the steps taken to prevent recurrence 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. A copy of the laboratory’s Certified Paramete r List at the time of the audit is attached. This list will reflect any changes made during the audit. Copies of the checklists completed during the inspection may be requested from this office. Thank you for your cooperation during the inspection. If you have questions or need additional information, please contact me at (919) 733-3908 Ext. 259. Sincerely, Beth Swanson Technical Assistance & Compliance Specialist Division of Water Resources Attachment cc: Tonja Springer, Todd Crawford, Cert #5320 On-Site Inspection Report L ABORATORY NAME: Pilkington North America Inc. NPDES PERMIT #: NC0049514 NC GENERAL PERMIT #: NCG070007 ADDRESS: 13121 South Rocky Ford Rd. Laurinburg, NC 28353 CERTIFICATE #: 5320 DATE OF INSPECTION: June 24, 2021 TYPE OF INSPECTION: Field Industrial Maintenance AUDITOR(S): Tonja Springer LOCAL PERSON(S) CONTACTED: Chris Graham and Jonathan Collins I.INTRODUCTION: 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 02H .0800 for the analysis of compliance monitoring samples. II.GENERAL COMMENTS: The inspection was performed remotely due to the coronavirus pandemic. The laboratory submitted the requested documentation and pictures of their reagents and instruments electronically on June 8, 2021, June 9, 2021, June 10, 2021, June 17, 2021 and June 24, 2021. Staff were forthcoming and responded well to suggestions from the auditor. All required Proficiency Testing (PT) Samples have been analyzed for the 2021 PT Calendar Year and the graded results were 100% acceptable. Contracted analyses are performed by TBL Environmental Laboratory Inc. (Certification #37), Environmental Chemists Inc. (Certification #94) and Element One Inc. (Certification #604) The laboratory submitted their Quality Assurance (QA) and/or Standard Operating Procedure (SOP) document(s) in advance of the inspection. These documents were reviewed, and editorial and substantive revision requirements and recommendations were made by this program outside of this formal report process. Although subsequent revisions were not requested to be submitted, they must be completed by January 2022. Page 2 #5320 Pilkington North America Inc. The laboratory is reminded that any time changes are made to laboratory procedures, the laboratory must update the QA/SOP document(s) and inform relevant staff. Any changes made in response to the pre-audit review or to Findings, Recommendations or Comments listed in this report must be incorporated to insure the method is being performed as stated, references to methods are accurate, and the QA and/or SOP document(s) is in agreement with each approved practice, test, analysis, measurement, monitoring procedure or regulatory requirement being used in the laboratory. In some instances, the laboratory may need to create an SOP to document how new functions or policies will be implemented. The laboratory is also reminded that SOPs are required to be reviewed at least every two years and are intended to describe procedures exactly as they are to be performed. Use of the word “should” is not appropriate when describing requirements (e.g., Quality Control (QC) frequency, acceptance criteria, etc.). Evaluate all SOP s for the proper use of the word “should”. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation A. Finding: The laboratory pH benchsheet do es not reference the approved method. Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data shall be traceable to the associated sample analyses and shall consist of the method or Standard Operating Procedure. Each item shall be recorded each time samples are analyzed. Analyses shall conform to methodologies found in Subparagraph (a)(1) of this Rule. Ref : 15A NCAC 02H .0805 (g) (2) (A). Comment: The reference method included the incorrect approval year. Comment: The method for which the lab is certified is: • pH – SM 4500 H+ B-2011 pH – Standard Methods, 4500 H+ B-2011 (Aqueous) B. Finding: Compliance Sample measurements are not bracketed with calibration and check standard buffers. Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (4). Requirement: Instruments are to be calibrated according to the manufacturer’s calibration procedure prior to analysis of samples each day compliance monitoring is performed. Calibration must include at least two buffers. The meter calibration must be verified with a third standard buffer solution (i.e., check buffer) prior to sample analysis. The calibration and check standard buffers must bracket the range of the samples being analyzed. Ref: NC WW/GW LC Approved Procedure for the Analysis of pH. Please submit an updated pH benchsheet containing compliance data with the report reply. Comment: The laboratory is calibrating the pH meter with 4.0 and 7.0 S.U. buffers and verifying the calibration with the 7.0 S.U. buffer. Comment: Compliance samples are being reported that are above 7.0 S.U. pH. Page 3 #5320 Pilkington North America Inc. Comment: The laborato ry sent an email on June 17, 2021 indicating that the pH meter is now being calibrated on the 4.0 S.U., 7.0 S.U. and 10.0 S.U. buffers and the 7.0 S.U. is used as the check buffer. IV. PAPER TRAIL INVESTIGATION: The paper trai l consisted of comparing original records (e.g., labo ratory benchsheets, logbooks, etc.) and contract laboratory reports to DMRs submitted to the North Carolina Division of Water Resources. Data were reviewed for Pilkington North America Inc. (NPDES pe rmit # NC0049514) for Januar y 2021, February 2021 and March 2021. The following errors were noted: Contract laboratory results for Hexavalent Chromium (1.34 µg/L), Total Chromium (<10 µg/L), Molybdenum (0.517 mg/L), and Fluoride (0.7 mg/L) were reported o n the D MR for March 3, 2021 instead of March 2, 2021. The permit requires the Oil & Grease values to be reported as lbs/day. The formula for converting to lbs/day is: Concentration (in mg/L) x daily flow (in MGD) x 8.34 (a constant, in lb/gal ) The client reports for January – Mar ch 2021 indicated the Oil & Grease values as <5.0 mg/L. The laboratory converted the client report values into lbs/day but used half the reporting limit(i.e., 2.5 mg/L) as the concentration. The mass loading should have been cal culated using 5.0 mg/L and reported as a less than value. (e.g., the daily flow on March 9, 2021 was 0.2438 MGD and the sample was reported as 5.09 mg/L, but should have been reported as <10 mg/L). To avoid questions of legality, it is recommended that you contact the appropriate Regional Of fice for guidance as to whether an amended DMR(s) will be required. A copy of this report will be made available to the Regional Office. V. CONCLUSIONS: Correcting the above-cited Findings will help this laboratory to produce quality data and meet Certification requirements. The inspector would like to thank the staff for their assistance during the inspection and data review process. Please respond to all Findings and include supporting documentation, implementation dates and steps taken to prevent recurrence for each corrective action. Report prepared by: Tonj a Springer Date: June 29, 2021 Report reviewed by: Michael Cumbus Date: June 30, 2021 Certificate Number:5320 Effective Date:1/1/2021 Expiration Date:12/31/2021 Lab Name:Pilkington North America Inc. Address:13121 South Rocky Ford Rd. Laurinburg, NC 28353- North Carolina Wastewater/Groundwater Laboratory Certification Certified Parameters Listing Date of Last Amendment:6/25/2021 The above named laboratory, having duly met the requirements of 15A NCAC 2H.0800, is hereby certified for the measurement of the parameters listed below. CERTIFIED PARAMETERS INORGANIC pH SM 4500 H+B-2011 (Aqueous) This certification requires maintance of an acceptable quality assurance program, use of approved methodology, and satisfactory performance on evaluation samples. Laboratories are subject to civil penalties and/or decertification for infractions as set forth in 15A NCAC 2H.0807.