Loading...
HomeMy WebLinkAbout#5460_2016_0112_BS_FINALINSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5460 Laboratory Name: PPG Industries Fiber Glass Products, Inc. Inspection Type: Field Maintenance Inspector Name(s): Beth Swanson, Gary Francies Inspection Date: 1/12/2016 Date Report Completed: 1/28/2016 Date Forwarded to Reviewer: 1/28/2016 Reviewed by: Jason Smith Date Review Completed: 1/29/2016 Cover Letter to use: ❑ Insp. Initial ❑ Insp. Reg. ❑ Insp. No Finding ❑ Insp. CP ® Corrected ❑ Insp. Reg. Delay Unit Supervisor/Chemist III: Gary Francies Date Received: 1 /29/2016 Date Forwarded to Linda: 2/15/2016 Date Mailed: 2/16/2016 Water Resources ENVIRONMEN TAI_ QUALITY PAT MCCRORY [ . l C w")' DONALD R. VAN DER VAART .VitChP1: S. JAY ZIMMERMAN r', m), February 16, 2016 5460 Ms. Brigette Tinsley PPG Industries Fiber Glass Products, Inc. P.O. Box 949 Lexington, NC 27292 SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Ms. Tinsley: Enclosed is a report for the inspection performed on January 12, 2016 by Beth Swanson and Gary Francies. Since the Finding(s) cited during the inspection were all corrected prior to the completion of the enclosed report, a response is not required. The staff is commended for taking the initiative in correcting the Findings in such a timely manner. 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, Gary Francies, Technical Assistance/Compliance Specialist Division of Water Resources Attachment cc: Beth Swanson Master File LABORATORY NAME: NPDES PERMIT #: ADDRESS: CERTIFICATE #: DATE OF INSPECTION: TYPE OF INSPECTION: AUDITOR(S): LOCAL PERSON(S) CONTACTED: INTRODUCTION: PPG Industries Fiber Glass Products, Inc. NC0004626 P.O. Box 949 Lexington, NC 27292 5460 January 12, 2016 Field Maintenance Beth Swanson and Gary Francies Brigette Tinsley, Eric Moten, and Terry Taylor 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. GENERAL COMMENTS: The facility is clean, well -organized, and has all the equipment necessary to perform the analyses. The lab personnel were eager to adopt recommendations and necessary changes and solve issues as soon as possible. Proficiency Testing r (PT) samples were analyzed for all certified parameters for the 2015 proficiency testing calendar year and the graded results were 100% acceptable. Contracted analyses are performed by Pace Analytical Services, Inc. — Huntersville (Certification #12). 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. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation Comment: The documentation of the annual temperature sensor verification did not include units of measure (i.e., °C). The North Carolina Administrative Code, 15 NCAC '2H .0805 (g) (1) states: Data pertinent to each analysis must be maintained for five years. Certified Data must consist of date collected, time collected, sample site, sample collector, and sample analysis time. The field benchsheets must provide a space for the signature or initials or the analyst, and proper units of measure for all analyses. Acceptable corrective action (i.e., units of measure (i.e., °C) were added to the temperature verification documentation) was performed during the inspection. No further response is necessary for this Finding. Page 2 #5460 PPG Industries Fiber Glass Products, Inc. Comment: The documentation of the annual temperature sensor verification did not include the serial number of the NIST thermometer used for comparison. The Approved Procedure for the Analysis of Temperature document states: The documentation must include the serial number of the NIST traceable thermometer that was used in the comparison Acceptable corrective action (i.e., the NIST thermometer serial number was added to the temperature verification documentation) was performed during the inspection. No further response is necessary for this Finding. Comment: Proper units of measure (i.e., ug/L) were not documented on the daily benchsheet for Total Residual Chlorine. The result column was labeled "mg/L or ug/L", with the intention that one of the units would be circled, which was not being done. The North Carolina Administrative Code, 15 NCAC 2H .0805 (g) (1) states: Data pertinent to each analysis must be maintained for five years. Certified Data must consist of date collected, time collected, sample site, sample collector, and sample analysis time. The field benchsheets must provide a space for the signature or initials or the analyst, and proper units of measure for all analyses. Notification of acceptable corrective action (i.e., an updated benchsheet with the results column only labeled as ug/L was implemented by January 23, 2016 was received by email on January 23, 2016. No further response is necessary for this Finding. Comment: The facility lacked traceability information. The facility was recording lot numbers for pH buffers and Total Residual Chlorine reagents on the daily benchsheet, but there was no documentation stating the vendor, expiration date, or date of receipt. The Quality Assurance Policies for Field Laboratories document 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. Notification of acceptable corrective action (i.e., the facility implemented by January 27, 2016 a laboratory receipt log with date received, vendor, and expiration date) was received by email on January 27, 2016. No further response is necessary for this Finding. Chlorine, Total Residual — Standard Methods, 4500 Cl G-2000 Comment: The low range calibration curve (i.e., program 86) had not been verified on the Hach DR1900. A contract laboratory performed the meter calibration verification and only verified the high level curve (i.e., program 82 with standard concentrations of 0.1, 0.2, 0.5, 1.0, and 2.0 mg/L) but assigned a true value for the mid -range Gel®standard on program 86. The laboratory was analyzing compliance samples and checking the Gel® standard on program 86 using that assigned value. The facility's permit limit is 28 ug/L and they were reporting sample concentrations below 25 ug/L as < 25 ug/L based off a curve verification performed on a separate instrument. The Approved Procedure for the Analysis of Total Residual Chlorine document states: Standard curve verification checks must be performed for the standard curve and/or program used for sample analysis. The concentrations of the calibration standards must bracket the concentrations of the samples analyzed. One of the standards must have a concentration equal to or below the lower reporting concentration for Total Residual Chlorine. The lower reporting limit must be less than or equal to the permit limit. Notification of acceptable corrective action (i.e., an acceptable calibration verification was performed on the low level program with calibration standard concentrations of 20, 50, 100, 200, and 400 ug/L on January 19, 2016 setting the current reporting limit at 20 ug/L. The Gel®standard concentration was verified as 204 ug/L on January 22, 2016.) was received by email on January 23, 2016. No further response is necessary for this Finding. pH — Standard Methods, 4500 H+ B-2000 Temperature — Standard Methods, 2550 B-2000 Comment: The analyst was writing a collection and analysis time for parameters measured in situ. The collection time was the time the probe entered the water and the analysis time was the time that the reading was deemed "stable". The Approved Procedure for the Analysis of pH and The Approved Procedure for the Analysis of Temperature documents state: Alternatively, one time may be documented for collection and analysis with the notation that samples are measured in situ or immediately at the Page 3 #5460 PPG Industries Fiber Glass Products, Inc. sample site. Notification of acceptable corrective action (i.e., a statement that one time is being recorded and an updated benchsheet stating one time is recorded for samples collected in situ was implemented by January 23, 2016) was received by email on January 23, 2016. No further response is necessary for this Finding. Proficiencv Testing Comment: The preparation of PT samples was not being documented. This only applies to the Total Residual Chlorine PT. The Proficiency Testing Requirements document states: 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. Notification of acceptable corrective action (i.e., a statement that the PT provider's preparation instructions will be initialed and dated from this point forward) was received by email on January 21, 2016. No further response is necessary for this Finding. Recommendation: The facility reported the 2015 pH PT sample to one decimal place. It is recommended that pH values be reported to 2 decimal places on the PT report, as stated in the vendor's instructions. Continue to report compliance data to 1 decimal. IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing original records (i.e., laboratory benchsheets) and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Resources. Data were reviewed for NPDES permit #NC0004626 for March, July, and September 2015. No transcription errors were detected. The facility appears to be doing a good job of accurately transcribing data. Please continue to pay close attention to the reporting limit for the "non -detect" Total Suspended Solids samples. V. CONCLUSIONS: All Findings noted during the inspection were adequately addressed prior to the completion of this report. The inspectors would like to thank the staff for its assistance during the inspection and data review process. No response is required. Report prepared by: Beth Swanson Date: January 28, 2016 Report reviewed by: Jason Smith Date: January 29, 2016