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HomeMy WebLinkAbout#5499_0520_finalpJ* ipA Ammmmom ENR 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 Page 2 #5499 Georgia Pacific Whiteville Plywood 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 Page 3 #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