HomeMy WebLinkAbout#5499_0520_finalpJ*
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North Carolina Department of Environment and Natural Resources
Pat McCrory Donald R. van der Vaart
Governor Secretary
May 26, 2015
5499
Doug Edmund
Georgia Pacific Whiteville Plywood
1980 Ga Pacific Road
Whiteville, NC 28472
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Edmund:
Enclosed is a report for the inspection performed on May 20, 2015 by Todd Crawford. Where
finding(s) are cited in this report, a response is required. Within thirty days of receipt, please supply
this office with a written item for item description of how these finding(s) were corrected 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.
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 (919)
733-3908.
Attachment
cc: Todd Crawford
Sincerely,
Dana Satterwhite, Environmental Program Supervisor
Division of Water Resources
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 1 FAX: 919-733-6241
Internet: www.dwglab.org
An Equal Opportunity l Affirmative Action Employer
INSPECTION 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:
5499
Georgia Pacific Whiteville Plywood
Industrial Maintenance
Todd Crawford
May 20, 2015
May 21, 2015
May 21, 2015
Tonia Springer
May 22, 2015
❑ Insp. Initial ® Insp. Reg.
❑ Insp. No Finding ❑ Insp. CP
❑ Corrected ❑ Insp. Reg. Delay
Dana Satterwhite
May 22, 2015
May 22, 2015
May 26, 2015 L
On -Site Inspection Report
LABORATORY NAME: Georgia Pacific Whiteville Plywood
NPDES PERMIT #: NC0005801
Stormwater Permit#: NCG210000
ADDRESS: 1980 Ga. Pacific Road
Whiteville, NC 28472
CERTIFICATE #: 5499
DATE OF INSPECTION: May 20, 2015
TYPE OF INSPECTION: Industrial Maintenance
AUDITOR(S): Todd Crawford
LOCAL PERSON(S) CONTACTED: Doug Edmund
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.
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 but the graded results have not yet been published.
Contracted analyses are performed by Vann Laboratories, Inc. (Certification #22).
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 needed 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. A system (e.g.,
traceable identifiers) must be in place that links standard/reagent preparation information to analytical
batches in which the solutions are used. Documentation of solution preparation must include the analyst's
initials, date of preparation, the volume or weight of standard(s) used, the solvent and final volume of the
solution. 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 and lots of pre -made standards are included in this
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requirement. Demonstration of acceptable corrective action was performed during the inspection (i.e., an
auditor -supplied Lab Supply Receipt Log was filled out with the pH buffers currently in-house and
immediately implemented). No further response is necessary for this finding.
Comment: The benchsheet for pH and Temperature was lacking the following required information:
® Sample site including facility name and location, ID, etc.
® Instrument identification.
The NC WW/GW LC Approved Procedure for the Analysis of pH and the NC WW/GW LC Approved
Procedure for the Analysis of Temperature documents both state: The following must be documented in
indelible ink whenever sample analysis is performed:
® Sample site including facility name and location, ID, etc.
® Thermometer/Instrument identification.
These requirements are new policies that have been implemented by our program since the last
inspection. Demonstration of acceptable corrective action (i.e., the computer generated benchsheet was
edited to include the facility name and meter identifications during the inspection and immediately
implemented). No further response is necessary for this finding.
Comment: The temperature correction factor was not posted on the meter. The NC WW/GW LC
Approved Procedure for the Analysis of Temperature document states: The following must be
documented in indelible ink whenever sample analysis is performed: The temperature correction (even if
it is zero) must be posted on the meter as well as in hard copy format (to be retained for five years).
Demonstration of acceptable corrective action (i.e., the placement of the temperature correction factor on
the meter) was performed during the inspection. No further response is necessary for this finding.
Comment: The current temperature correction factor is 0.0°C. However, please be reminded that any
non -zero temperature correction factors must be applied to the samples measured and reported.
pH — Standard Methods, 4500 H+B-2000
Comment: The laboratory was not analyzing a check buffer on each analysis day. The NC WW/GW
LC Approved Procedure for the Analysis of pH document states: The meter must be calibrated with at
least two buffers. In addition to the calibration buffers the meter calibration must be verified with a third
standard buffer solution. The calibration and check standard buffers must bracket the range of the
samples being analyzed. The check standard buffer must read within ±0 1 S U to be acceptable. If the
meter verification does not read within ±0.1 S.U., the meter must be recalibrated before any samples
are analyzed. Notification of acceptable corrective action was received during the inspection (i.e., the
computer generated benchsheet was edited to include space to document the analysis of the
calibration check buffer and the analyst stated that analysis and documentation of it would begin
immediately). No further response is necessary for this finding.
Proficiency Testing
A. Finding: The laboratory is not analyzing Proficiency Testing (PT) samples in the same manner as
environmental samples.
Requirement: 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
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#5499 Georgia Pacific Whiteville Plywood
samples analyzed according to the requirements of 15A NCAC 2H .0800. Ref: Proficiency Testing
Requirements, February 20, 2012, Revision 1.2.
Comment: The laboratory's common practice was to analyze a known standard along with the PT
sample as additional quality control. Since this is not performed with all environmental samples, it
is considered additional quality control. However, known samples are recommended when
analyzing remedial PT samples as part of the troubleshooting and corrective action process.
B. Finding: The laboratory is not documenting Proficiency Testing (PT) sample analyses in the
same manner as environmental samples.
Requirement: All PT sample analyses must be recorded in the daily analysis records as for any
environmental sample. This serves as the permanent laboratory record. Ref: Proficiency
Testing Requirements, February 20, 2012, Revision 1.2.
Comment: The common laboratory practice was to document the result on the reporting form
only. The analysis of PT samples is designed to evaluate the entire process used to routinely
report environmental analytical results; therefore, PT samples must be analyzed and the
process documented in the same manner as environmental samples.
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 January, February and March, 2015. No transcription errors
were detected. The facility appears to be doing a good job of accurately transcribing data.
V. CONCLUSIONS:
Correcting the above -cited findings will help this lab to produce quality data and meet certification
requirements. The inspector would like to thank the staff for its assistance during the inspection and data
review process. Please respond to all findings.
Report prepared by: Todd Crawford Date: May 21, 2015
Report reviewed by: Tonja Springer Date: May 22, 2015