Loading...
HomeMy WebLinkAbout#5024_0513finalTS_2015_1 CDENR North Carolina department of Environment and Natural Resources Pat McCrory Donald R, van der Vaart Governor Secretary June 9, 2015 5024 Durafiber Technologies Marty Stewart 338 Pea Ridge Road New Hill, NC 27562-8951 Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Stewart: Enclosed is a report for the inspection performed on May 13, 2015 by Tonja Springer. 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: Tonja Springer 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 i FAX: 919-733-6241 Internet: www.dwglab.org An Equal Opportunity t Affirmative Action Employer INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5024 Laboratory Name: Durafiber Technologies Inspection Type: Field Maintenance Inspector Name(s): Tonia Springer Inspection Date: May 13, 2015 Date Report Completed: June 4, 2015 Date Forwarded to Reviewer: June 4, 2015 Reviewed by: Nick Jones Date Review Completed: June 8, 2015 Cover Letter to use: ❑ Insp. Initial ® Insp. Reg. ❑ Insp. No Finding ❑ Insp. CP ❑ Corrected ❑ Insp. Reg. Delay Unit Supervisor/Chemist III: Dana Satterwhite Date Received: June 8, 2015 Date Forwarded to Linda: June 9 2015 Date Mailed: June 9 2015 On -Site Inspection Report LABORATORY NAME: NPDES PERMIT #: ADDRESS: CERTIFICATE #: DATE OF INSPECTION: TYPE OF INSPECTION: AUDITOR(S): LOCAL PERSON(S) CONTACTED: INTRODUCTION: Durafiber Technologies NC0001899 338 Pea Ridge Road New Hill, NC 27562-8951 5024 May 13, 2015 Field Maintenance Tonja Springer Marty Stewart, Larry Murray and Earl Beal 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 laboratory was clean and well organized. The facility has all the equipment necessary to perform the analyses. PT samples for the 2015 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, 2015. Current quality assurance policies for Field Laboratories, an example benchsheet and approved procedures for the analysis of the facility's currently certified parameters were provided at the time of the inspection. Contracted analyses are performed by Pace Analytical Services, Inc. - Huntersville (Certification #12) and Pace Analytical Services, Inc. - Raleigh (Certification #67). Per an email submitted on 5/22/2015, the laboratory's name changed from Performance Fibers, Inc. (PFI) to Durafiber Technologies. An updated certificate with the laboratory's new name will be sent under separate cover. Per an email submitted on 5/22/2015, the laboratory requested to drop Conductivity. These analyses are being performed by Pace Analytical Services, Inc. - Huntersville (Certification #12). An amended certificate reflecting the deletion of Conductivity SM 2510 B-1997 (Aqueous) was mailed on June 8, 2015 with an effective date of May 22, 2015. The requirement associated with Findings A, B and F have been implemented by our program since the last inspection. Page 2 #5024 Durafiber Technologies III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation Comment: Several instances of writing over a number as a means of error correction were observed. Error corrections were not initialed or dated. The Quality Assurance Policies for Field Laboratories document states: All documentation errors must be corrected by drawing a single line through the error so that the original entry remains legible. Entries shall not be obliterated by erasures or markings. Wite- Out®, correction tape or similar products designed to obliterate documentation are not to be used. Write the correction adjacent to the error. The correction must be initialed by the responsible individual and the date of change documented. All data and log entries must be written in indelible ink. Pencil entries are not acceptable. Notification of acceptable corrective action (i.e., a statement that "All errors will be corrected by drawing a single line thru it and initialed and dated." with an implementation date of 5/13/2015) was received by email on 5/22/2015. No further response is necessary for this finding. A. Finding: The laboratory needed to increase the documentation of purchased reagents. Requirement: 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. Consumable materials such as pH buffers and lots of pre -made standards are included in this requirement. Ref: Quality Assurance Policies for Field Laboratories. Please submit a copy of an updated completed benchsheet [or a log form may be used] that includes the required traceability information and an implementation date with the response to this report. pH — Standard Methods, 4500 H+ B-2000 Comment: Numbers ending with a "T are not properly rounded when reporting pH results on the Discharge Monitoring Reports (DMR). The laboratory is rounding up when the number preceding a 5 is even. For example 7.45 is reported as 7.5 and not 7.4. Standard Methods, 1050 B-2006. (2) states: Round off by dropping digits that are not significant. If the digit 6, 7, 8, or 9 is dropped, increase preceding digit by one unit; if the digit 0, 1, 2, 3, or 4 is dropped, do not alter preceding digit. If the digit 5_is dropped, round off preceding digit to the nearest even number: thus 2.25 becomes 2.2 and 2.35 become 2.4. Notification of acceptable corrective action (i.e., a statement that "Our policy of rounding moving forward will be the following: Even numbers are not rounded up when the next number is 5 or below." "Odd numbers are rounded up for 5 and above." with an implementation date., of 5/13/2015) was received by email on 5/22/2015. No further response is necessary for this finding. pH — Standard Methods, 4500 H+ B-2000 Dissolved Oxygen — Standard Methods, 4500-0 G-2001 B. Finding: The laboratory benchsheets were lacking pertinent data: Instrument identification. Requirement: The following must be documented in indelible ink whenever sample analysis is performed: Instrument identification. Ref: NC WW/GW LC Approved Procedure for the Analysis of pH and NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen. Please submit a copy of an updated benchsheet that includes sample results with the response to this report. Page 3 #5024 Durafiber Technologies Temperature — Standard Methods, 2560 B-2000 C. Finding: The temperature sensor on the pH meter used to obtain reported temperature values has not been checked against a National Institute of Standards and Technology (NIST) traceable thermometer within the past 12 months. Requirement: Thermometers and temperature measuring devices, used to measure temperature for compliance monitoring, must be checked every 12 months against a NIST traceable thermometer. The thermometer/meter readings must be less than or equal to 1°C from the NIST traceable thermometer reading. The documentation must include the serial number of the NIST traceable thermometer that was used in the comparison. Document any correction that applies on both the thermometer/meter and on a separate sheet to be filed. Ref: NC WW/GW LC Approved Procedure for the Analysis of Temperature. Please submit a copy of the NIST traceable calibration verification with the response to this report. D. Finding: The laboratory is not documenting the following information for compliance Temperature measurements: time of analysis and collection time. Requirement: The following must be documented in indelible ink whenever sample analysis is performed: Date and time of sample collection, date and time of sample analysis. Alternatively, one time may be documented for collection and analysis with the notation that samples are measured in situ or immediately at the sample site. Ref: NC WW/GW LC Approved Procedure for the Analysis of Temperature. Please submit 2 months of updated completed benchsheets that include sample results with the response to this report. Comment: The reported temperature readings are recorded on the daily log and not the benchsheet. The daily log does have a time documented, but it is not documented clearly to indicate that it is time of analysis. Only "time" is documented. The method reference is not documented on the daily log. Comment: An updated benchsheet that merges the laboratory's daily log information and the benchsheet was provided to the laboratory by email on 6/2/2015. There is space provided on this benchsheet to document Temperature and the required supporting information. Recommendation: It is recommended that the method reference be documented on the benchsheet. Dissolved Oxygen — Standard Methods, 4500-0 G-2001 E. Finding: The meter's calibration is being performed, but it is not documented each analysis day. Requirement: The following must be documented in indelible ink whenever sample analysis is performed. Meter calibration and meter calibration time(s). Ref: NC WW/GW LC Approved Procedure for Analysis of Dissolved Oxygen (DO). Requirement: Instruments are to be calibrated according to the manufacturer's calibration procedure prior to analysis of samples each day compliance monitoring is performed. Ref: NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen (DO). Please submit 2 months of completed benchsheets with the response to this report. Page 4 #5024 Durafiber Technologies Requirement: The laboratory must document each time that a calibration is performed. Calibration documentation must include the following, where applicable to the instrument used and the type of calibration performed: elevation, temperature, barometric pressure (in mmHg), salinity, slope, or %efficiency. Simply recording a final reading (in mg/L) for instruments that auto calibrate (e.g., LDO sensors and Membrane Electrodes that AUTOCAL) is also acceptable. Ref: NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen (DO). Comment: There is a column labelled as "Adjusted Air Calibration" on the benchsheet for DO but nothing is being documented in the space below the header. The value obtained when the meter is calibrated is the value that must be written in this space. Proficiency Testing F. 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 samples analyzed according to the requirements of 15A NCAC 2H .0800. Ref: Proficiency Testing Requirements, February 20, 2012, Revision 1.2. Comment: The laboratory was analyzing pH PT samples multiple times and reporting the first sample result. Environmental samples are not analyzed and reported in this manner. Comment: The laboratory's common practice was also 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. 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 and March, 2015. The following errors were noted: Date Parameter Location Value on Benchsheet Value on DMR 3/11 /2015 pH Effluent 7.45 s.0 7.5 s.u* 3/23/2015 pH Effluent 7.01 s.u. 7.3 s.u. 3/24/2015 pH Effluent 7.35 s.u. 7.0 s.u. * This appears to be a rounding error as noted in the corrected finding under the pH subheading In order to avoid questions of legality, it is recommended that you contact the appropriate Regional Office for guidance as to whether amended Discharge Monitoring Reports will be required. A copy of this report will be made available to the Regional Office. Page 5 #5024 Durafiber Technologies V. CONCLUSIONS: Correcting the above -cited findings and implementing the recommendation 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 and include an implementation date for each corrective action. Report prepared by: Tonja Springer Date: June 4, 2015 Report reviewed by: Nick Jones Date: June 8, 2015