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HomeMy WebLinkAbout#5464_2016_0203_AO_FINALINSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: Laboratory Name: Inspection Type: Inspector Name(s): Inspection Date: Date Report Completed: Date Forwarded to Reviewer: Reviewed by: Date Review Completed: Cover Letter to use: Unit Supervisor/Chemist III: Date Received: Date Forwarded to Linda: Date Mailed: 5464 Georgia-Pacific Chemicals, LLC Field Maintenance Anna Ostendorff, Gary Francies and Todd Crawford February 3, 2016 March 3, 2016 March 3, 2016 Beth Swanson March 4, 2016 ❑ Insp. Initial ❑ Insp. No Finding ® Corrected Gary Francies March 4, 2016 March 7, 2016 March 8, 2016 ❑ Insp. Reg. ❑ Insp. CP ❑ Insp. Reg. Delay PAT MCCRORY ,f err, y t Writer Resources ENVIRONMEN TAB. QUAL. 'Y March 7, 2016 5464 Mr. Tim Riddick Georgia-Pacific Chemicals, LLC PO Box 368 Conway, NC 27820 DONALD R. VAN DER VAART S. JAY ZIMMERMAN SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Riddick: Enclosed is a report for the inspection performed on February 3, 2016 by Anna Ostendorff, Gary Francies and Todd Crawford. I apologize for the delay in getting this report to you. 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 me at (828) 296-4677. Sincerely, Gary Francies, Technical Assistance/Compliance Specialist Division of Water Resources Attachment cc: master file Anna Ostendorff Water Sciences 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 Phone: 919-733-39081 FAX: 919-733-6241 Internet: http:lldeg.nc.gov/aboutidivisions/water•resources/water-resources-datalwater-sciences•home-pagellaboratory-certification-branch On -Site Inspection Report LABORATORY NAME: WATER QUALITY PERMIT #: STORMWATER PERMIT #: ADDRESS: CERTIFICATE #: DATE OF INSPECTION: TYPE OF INSPECTION: AUDITOR(S): LOCAL PERSON(S) CONTACTED: INTRODUCTION: Georgia-Pacific Chemicals, LLC WQ0002012 NCS000251 PO Box 368 Conway, NC 27820 5464 February 3, 2016 Field Maintenance Anna Ostendorff, Gary Francies, and Todd Crawford Tim Riddick, Angie Smith, and Walter Lee 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 has all the equipment necessary to perform the analyses. Proficiency Testing (PT) samples have been analyzed for all certified parameters for the 2015 proficiency testing calendar year and the graded results were 100% acceptable. Contracted analyses are performed by Universal Laboratories (Certification #543). 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 laboratory needs to increase the documentation of purchased materials and reagents. 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. 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 are included in this requirement. Acceptable corrective action (i.e., a traceability document was provided by the Page 2 #5464 Georgia-Pacific Chemicals, LLC inspector and implemented immediately) was performed during the inspection. No further response is necessary for this Finding. Comment: The laboratory benchsheet was lacking pertinent data: Instrument identification. The NC WW/GW LC Approved Procedure for the Analysis of pH document states: The following must be documented in indelible ink whenever sample analysis is performed: Instrument Identification. Acceptable corrective action (i.e., instrument identification was added to the pH benchsheets for stormwater and surface irrigation) was performed by the laboratory and observed by the inspector to be adequate during the inspection. No further response is necessary for this Finding. Comment: The laboratory was not documenting all pertinent information. The North Carolina Administrative Code, 15A 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 of the analyst, and proper units of measure for all analyses. Acceptable corrective action (i.e., sample collection time, analysis time, sample site identification, analyst initials, and proper units of measure were added to the spray irrigation benchsheet; analysis time and proper units of measure were added to the stormwater benchsheet) was performed by the laboratory and observed by the inspector to be adequate during the inspection. No further response is necessary for this Finding. Proficiency Testing Recommendation: It is recommended analysts alternate performing Proficiency Testing (PT) analyses. The Proficiency Testing Requirements document states that laboratories shall ensure that PT samples are equally distributed among personnel trained and qualified for the relevant tests, which represent the routine operation of the work group at the time the PT study is conducted. Comment: The laboratory is not documenting PT sample analyses in the same manner as environmental samples. The Proficiency Testing Requirements, February 20, 2012, Revision 1.2 document states: All PT sample analyses must be recorded in the daily analysis records as for any environmental sample. This serves as the permanent laboratory record. Notification of acceptable corrective action (i.e., a statement that the instrument ID, analysis time and analyst initials will be documented the next time PT samples are performed) was received by e-mail on 2/16/16. No further response is necessary for this Finding. pH — Standard Methods, 4500 H+ B-2000 Comment: Values were reported that exceed the method specified accuracy of 0.1 units. Standard Methods, 4500 H+ B-2000, (6) states in part: However, ± 0.1 pH unit represents the limit of accuracy under normal conditions, especially for measurement of water and poorly buffered solutions. For this reason, report pH values to the nearest 0.1 pH unit. Notification of acceptable corrective action (i.e., a statement that pH results would be reported to 0.1 units with an implementation date of 2/16/16) was received by e-mail on 2/16/16. No further response is necessary for this Finding. Page 3 #5464 Georgia-Pacific Chemicals, LLC IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks, etc.) and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Resources. Data were reviewed for Georgia-Pacific Chemicals, LLC (permit # WQ0002012) for May, June and October, 2015. No transcription errors were detected. The facility appears to be doing a good job of accurately transcribing data. V. CONCLUSIONS: All Findings noted during the 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: Anna Ostendorff Date: March 3, 2016 Report reviewed by: Beth Swanson Date: March 4, 2016