HomeMy WebLinkAbout#5479_09_2012_FINAL�@Al
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P. E.
Governor Director
October 30, 2012
5479
Mr. Joseph Cote, Jr
Belmont Textile Machinery Company
P.O. Box 568
Mount Holly, NC 28120
Dee Freeman
Secretary
SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Cote:
Enclosed is a report for the inspection performed on September 26, 2012 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 828-296-4677.
Sincerely,
Gary Francies
Certification Unit Supervisor
Laboratory Section
CC: Jason Smith
Chet Whiting
Master File
DENR DWQ Laboratory Section NC Wastewater/Groundwater Laboratory Certification Branch
1623 Mail Service Center, Raleigh, North Carolina 27699-1623
Location: 4405 Reedy Creek Road. Raleigh, North Carolina 27607-6445
Phone: 919-733-3908 \ FAX: 919-733-6241 One
Internet: www.dwglab.org North . a.roli 2a
An Equal Opportunity \ Affirmative Action Employer Naturally
INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #: 5479
Laboratory Name: Belmont Textile Machinery Company
Inspection Type: Field Maintenance
Inspector Name(s): Jason Smith
Inspection Date: September 26, 2012
Date Report Completed: October 18, 2012
Date Forwarded to Reviewer: October 19, 2012
Reviewed by: Chet Whitintq
Date Review Completed: October 19 2012
Cover Letter to use: ❑ Insp. Initial ❑ Insp. Reg.
❑ Insp. No Finding ❑ Insp. CP
® Corrected
Unit Supervisor: Gary Francies
Date Received: 10/22/2012
Date Forwarded to Linda: 10/30/2012
Date Mailed: l 13 1 11za
LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
INTRODUCTION:
On -Site Inspection Report
Belmont Textile Machinery Company
NCO023540
P.O. Box 568
Mount Holly, NC 28120
5479
September 26, 2012
Field Maintenance
Jason Smith
Joseph Cote, Jr.
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 lab has all the equipment_ necessary to perform the analyses. Proficiency Testing (PT) samples have
been analyzed for all certified parameters for the 2012 proficiency testing calendar year and the graded
results were acceptable. Contracted analyses are performed by K&W Laboratories (Certification
#559).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.
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Documentation
Comment: The laboratory needed to increase the documentation of purchased materials and reagents,
as well as documentation of standards and reagents prepared in the laboratory. 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 requirement. This requirement is a new policy that
has been implemented by our program since the last inspection. Notification of acceptable corrective
action (i.e., preparation of Potassium Permanganate will be documented when made) was received by
email on September 26, 2012. Laboratory personnel created a traceability log for purchased materials
and reagents at the time of the inspection. No further response is necessary for this finding.
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#5479 Belmont Textile Machinery Company
Comment: Error corrections were not dated when performed. 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 chancre documented. All data and log entries must be written in
indelible ink. Pencil entries are not acceptable. This requirement is a new policy that has been
implemented by our program since the last inspection. Notification of acceptable corrective action (i.e.,
error corrections will be dated when performed) was received by email on September 26, 2012. No
further response is necessary for this finding.
Quality Control
Comment: The auto-pipettor has not been calibrated. The Quality Assurance Policies for Field
Laboratories document states: Mechanical volumetric liquid -dispensing devices (e.g., fixed and
adjustable auto-pipettors, bottle -top dispensers, etc.) must be calibrated at least every twelve months
and documented. Each liquid -dispensing device must meet the manufacturer's statement of accuracy.
For variable volume devices used at more than one setting, check the accuracy at the maximum,
middle and minimum values. Testing at more than three volumes is optional. When a device capable of
variable settings is dedicated to dispense a single specific volume, calibration is required at that setting
only. This requirement is a new policy that has been implemented by our program since the last
inspection. Notification of acceptable corrective action (i.e., the auto-pipettor will be calibrated prior to
being used) was received by email on September 26, 2012. No further response is necessary for this
finding.
Comment: The auto-pipettor is used to prepare the Total Residual Chlorine standards for verification of
the instrument's internal curve and to prepare the Proficiency Testing sample for analysis.
Proficiency Testing
Comment: The preparation of Proficiency Testing (PT) samples was not documented. The Proficiency
Testing Requirements, February 20, 2012, Revision 1.2. 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. The diluted PT sample becomes a
routine environmental sample and is added to a routine sample batch for analysis. This requirement is
a new policy that has been implemented by our program since the last inspection. Notification of
acceptable corrective action (i.e., PT instructions will be signed and dated to document preparation)
was received by email on September 26, 2012. No further response is necessary for this finding.
Comment: PT samples were not analyzed in the same manner as environmental samples. A known
sample was analyzed with the PT samples and multiple analyses were performed. The Quality
Assurance Policies for Field Laboratories document states: 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. This requirement is a new policy that has been implemented by our program since the last
inspection. Notification of acceptable corrective action (i.e., PT will be analyzed in the same manner as
environmental samples) was received by email on September 26, 2012. 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 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
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#5479 Belmont Textile Machinery Company
environmental sample. This serves as the permanent laboratory record. This requirement is a new policy
that has been implemented by our program since the last inspection. During the inspection, laboratory
personnel created an identical benchsheet to their normal benchsheet, except labeled for the PT, to be
used for PT analysis documentation. No further response is necessary for this finding.
Comment: Proper method codes were not reported with the PT results. The Proficiency Testing
Requirements, February 20, 2012, Revision 1.2. document states: Laboratories must also be careful to
designate the correct method code(s) being used for each PT sample result. To ensure that you are
reporting the correct method, review your certificate attachment (i.e., certified parameter list). If you are
using a method that is not listed on your certificate attachment (i.e., certified parameter list), please
contact your auditor so that your certificate can be updated. The method must include the entire method
reference as is written on your certificate attachment (i.e., certified parameter list). This requirement is a
new policy that has been implemented by our program since the last inspection. Notification of
acceptable corrective action (i.e., PT results will be reported with the correct method codes) was
received by email on September 26, 2012. No further response is necessary for this finding.
pH — Standard Methods 4500 H+ B
Comment: Values were reported that exceed the method specified accuracy of 0.1 units. Standard
Methods, 4500 H+ B-2000, (6) states: By careful use of a laboratory pH meter with good electrodes, a
precision of ±0.02 unit and an accuracy of ±0.05 unit can be achieved. 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. The Discharge
Monitoring Report form was edited during the inspection to round pH results to one decimal place. No
further response is necessary for this finding.
Temperature — Standard Methods 2550 B
pH — Standard Methods 4500 H+ B
Comment: Temperature and pH are analyzed at the time of collection, but the benchsheet indicated that
they were analyzed later along with the Total Residual Chlorine sample. 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, samples site,
sample collector, and sample analysis time. The field benchsheets must provide a space for the
signature of the analyst, and proper units of measure for all analyses. Laboratory personnel updated
the benchsheet to state "pH and Temperature analyzed at time of sampling" during the inspection. No
further response is necessary for this finding.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing laboratory benchsheets and contract lab reports to Discharge
Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data were
reviewed for May, June, July, and August, 2012. The following errors were noted:
Date
Parameter
Location
Value on Benchsheet
Value on DMR
(*Contract Lab Data)
6/4/12
Total Residual
Effluent
12,ug/L
15 mg/L
Chlorine
6/12/12
Biochemical
Effluent
4.2 mg/L *
2.4 mg/L
Oxygen Demand
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#5479 Belmont Textile Machinery Company
8/19/12
Total Residual
Effluent
No result
12,ug/L
Chlorine
8/21/12
Total Residual
Effluent
12,ug/L
<10 /jg/L
Chlorine
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
Report reviewed by: Chet Whiting
Date: October 18, 2012
Date: October 19, 2012