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INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #: 5489
Laboratory Name: PPG Industries Fiber Glass Products, Inc.
Inspection Type: Field Maintenance
Inspector Name(s): Jason Smith
Inspection Date: February 16, 2016
Date Report Completed: March 14, 2016
Date Forwarded to Reviewer: March 14, 2016
Reviewed by: Beth Swanson
Date Review Completed: March 15, 2016
Cover Letter to use: Insp. Initial Insp. Reg.
Insp. No Finding Insp. CP
Corrected Insp. Reg. Delay
Unit Supervisor/Chemist III: Todd Crawford
Date Received: March 18, 2016
Date Forwarded to Admin: March 31, 2016
Date Mailed: March 31, 2016
_____________________________________________________________________
PAT MCCRORY
Governor
DONALD R. VAN DER VA ART
Secretary
S. JAY ZIMMERMAN
Director
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: 919-733-3908 \ FAX: 919-733-6241
Internet: http://deq.nc.gov/about/divisions/water-resources/water-resources-data/water-sciences-home-page/laboratory-certification-branch
March 31, 2016
5489
Mr. Richard Young
PPG Industries Fiber Glass Products, Inc.
940 Washburn Switch Road
Shelby, NC 28150-
SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Young:
Enclosed is a report for the inspection performed on February 16, 2016, by Jason Smith. 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
electronic mail, or if you have questions or need additional information, please contact me at (919) 733-
3908 ext. 251.
Sincerely,
Todd Crawford
Technical Assistance & Compliance Specialist
NC WW/GW Laboratory Certification Branch
Attachment
cc: Dana Satterwhite, Jason Smith, Central Files
On-Site Inspection Report
LABORATORY NAME: PPG Industries Fiber Glass Products, Inc.
NPDES PERMIT #: NC0004685
ADDRESS: 940 Washburn Switch Road
Shelby, NC 28150
CERTIFICATE #: 5489
DATE OF INSPECTION: February 16, 2016
TYPE OF INSPECTION: Field Maintenance
AUDITOR(S): Jason Smith
LOCAL PERSON(S) CONTACTED: Richard Young, John Littlejohn, Guy O’Connor, Linda Bridges, and
Tim Ellis
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 2H .0800 for the analysis of environmental samples.
II. GENERAL COMMENTS:
The facility has all the equipment necessary to perform the analyses and the laboratory is commended for
voluntarily maintaining Standard Operating Procedures (SOPs) for all parameters.
Proficiency Testing (PT) samples for the 2016 proficiency testing calendar year have not yet been
analyzed. The laboratory is reminded that these results must be submitted to this office directly from the
vendor by September 30, 2016.
Contracted analyses are performed by Pace Analytical Services, Inc. - Huntersville (Certification #12) and
Research & Analytical Laboratories (Certification #34).
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.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
Comment: The traceability log did not include the vendor. 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 Requirement is a new policy that has been implemented
by our program since the last inspection. Notification of acceptable corrective action (i.e., a statement
that the traceability log was revised to include vendor and put into use on February 24, 2016) was
received by email on February 24, 2016. No further response is necessary for this Finding.
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#5489 PPG Industries Fiber Glass Products, Inc.
Comment: Instrument identification was not documented on the benchsheet. The NC WW/GW LC
Approved Procedure for the Analysis of pH, NC WW/GW LC Approved Procedure for the Analysis of
Specific Conductance (Conductivity), NC WW/GW LC Approved Procedure for the Analysis of
Dissolved Oxygen, NC WW/GW LC Approved Procedure for the Analysis of Temperature, and NC
WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine documents state: The
following must be documented in indelible ink whenever sample analysis is performed: Instrument
identification. This Requirement is a new policy that has been implemented by our program since the last
inspection. Notification of acceptable corrective action (i.e., a statement that all benchsheets have been
updated to include the instrument serial number and put into use on February 24, 2016) was received
by email on February 24, 2016. No further response is necessary for this Finding.
Proficiency Testing
Recommendation: The laboratory has a new automatic pipettor that will be used for preparation of the
Total Residual Chlorine (TRC) Proficiency Testing (PT) sample. It is recommended that the automatic
pipettor have its accuracy verified prior to use. The laboratory must verify the automatic pipettor
accuracy once every twelve months (preferably shortly before being used for PT preparation).
Comment: Preparation of the TRC PT sample was not documented. The NC WW/GW LC 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. This Requirement is a new policy that has been implemented by our program
since the last inspection. Notification of acceptable corrective action (i.e., a statement that PT sample
preparation will be documented and filed with the results beginning with the next PT study and the SOP
has been updated to reflect this) was received by email on February 24, 2016. No further response is
necessary for this Finding.
Comment: The laboratory was not analyzing PT samples in the same manner as environmental
samples. Known standards from the PT vendor were analyzed along with the PT samples, but not with
environmental samples. The NC WW/GW LC Proficiency Testing Requirements document states: All
PT samples are to be analyzed and the results reported in a manner consistent with the routine
analysis and reporting requirements of compliance samples and any other samples analyzed according
to the requirements of 15A NCAC 2H .0800. Notification of acceptable corrective action (i.e., a
statement that known standards from the vendor will be performed annually, but more than 30 days
prior to PT sample analysis beginning this year and the SOP was updated to reflect this) was received
by email on February 24, 2016. No further response is necessary for this Finding.
Comment: The laboratory was not documenting PT sample analyses in the same manner as
environmental samples. The NC WW/GW LC Proficiency Testing Requirements 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 PT sample analyses will be documented on the daily benchsheets beginning with the
next PT study and the SOP was updated to reflect this) was received by email on February 24, 2016.
No further response is necessary for this Finding.
Temperature – Standard Methods, 2550 B-2000 (Aqueous)
Comment: Samples at Outfall 002 were not analyzed within the holding time (immediately). The
laboratory was under the impression that samples were to be analyzed within 15 minutes. The Code of
Federal Regulations, Title 40, Part 136; Federal Register Vol. 77, No. 97, May 18, 2012; Table II
states: Temperature Maximum Holding Time: Analyze. Notification of acceptable corrective action (i.e.,
a statement that the benchsheet and SOP were updated February 24, 2016 to indicate immediate
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#5489 PPG Industries Fiber Glass Products, Inc.
analysis and Temperature samples are now analyzed immediately) was received by email on February
24, 2016. No further response is necessary for this Finding.
Total Residual Chlorine – Hach 10014 ULR (Aqueous)
Comment: Hach Absorbance check standards were being used for daily meter verification. The NC
WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine states: General absorbance
standards (e.g., DR/check) supplied by some manufacturers cannot be used for the check standard. Gel-
type standards may be used for this purpose. Notification of acceptable corrective action (i.e., a
statement that Hach TRC gel standards were ordered, received, assigned a true value, and will be
analyzed each day of sample analysis beginning the next time samples are analyzed) was received by
email on March 14, 2016. No further response is necessary for this Finding.
Conductivity – Standard Methods, 2510 B-1997 (Aqueous)
Comment: The Automatic Temperature Compensator (ATC) has not been verified. The NC WW/GW LC
Approved Procedure for the Analysis of Specific Conductance (Conductivity) states: The ATC must be
verified annually (i.e., 12 months) at two temperatures by analyzing a standard or sample at 25°C (the
temperature that conductivity values are compensated to) and a temperature(s) that brackets the
temperature ranges of the environmental samples routinely analyzed. This may require the analysis of a
third temperature reading that is > 25°C. Notification of acceptable corrective action (i.e., a statement
that the ATC verification will be performed every 12 months and a copy of an acceptable ATC
verification performed on March 17, 2016) was received by email on March 11 and 18, 2016. No
further response is necessary for this Finding.
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 th e North Carolina
Division of Water Resources. Data were reviewed for May and July, 2015. The following errors were
noted:
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 made available to the Regional Office.
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: Jason Smith Date: March 14, 2016
Report reviewed by: Beth Swanson Date: March 15, 2016
Date Parameter Location Value on Benchsheet Value on DMR
5/12/15 pH Effluent 6.9 S.U. 6.2 S.U.
5/12/15 Dissolved Oxygen Effluent 6.2 mg/L 6.9 mg/L