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Home My WebLink About#5585 12-Final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5585 Laboratory Name: Envision Plastics Inspection Type: Field Initial Inspector Name(s): Jeffrey R. Adams Inspection Date: August 23, 2012 Date Report Completed: August 28, 2012 Date Forwarded to Reviewer: August 28, 2012 Reviewed by: Todd Crawford Date Review Completed: August 31, 2012 Cover Letter to use: X Insp. Initial Insp. Reg. Insp. No Finding Insp. CP __ Corrected Unit Supervisor: Dana Satterwhite Date Received: September 11, 2012 Date Forwarded to Linda: October 5, 2012 Date Mailed: October 8, 2012 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Envision Plastics NPDES PERMIT #: NC0024881 ADDRESS: 606B Walters Street Reidsville, NC 27320 CERTIFICATE #: 5585 DATE OF INSPECTION: August 23, 2012 TYPE OF INSPECTION: Field Initial AUDITOR(S): Jeffrey R. Adams LOCAL PERSON(S) CONTACTED: Melvernia Holly 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 laboratory was clean and records were well organized. Some quality control procedures need to be implemented. The laboratory is currently analyzing samples only for pH for pretreatment monitoring. The facility reports data to the City of Reidsville pretreatment program. The laboratory was given a packet containing North Carolina Laboratory Certification quality control policies and approved procedures for field analyses during the inspection. Contracted analyses are performed by Meritech, Inc. (Certification #165). III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Traceability A. Finding: The laboratory needs to increase the documentation of purchased materials and reagents (i.e., pH buffers). 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. 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 Page 2 #5585 Envision Plastics standards are included in this requirement. Ref: Quality Assurance Policies for Field Laboratories. Proficiency Testing B. Finding: The laboratory is not documenting Proficiency Testing (PT) sample analyses in the same manner as environmental samples (i.e., on a laboratory benchsheet or field notebook). 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. pH – Standard Methods, 18th Edition, 4500 H+ B C. Finding: The proper units of measure (i.e., S.U. for pH) are not documented on the benchsheet. Requirement: Data pertinent to each analysis must be maintained for five years. Certified Data must consist of date collected, time collected, sample site, sample collector, and sample analysis time. The field bench sheets must provide a space for the signature or initials of the analyst, and proper units of measure for all analyses. Ref: 15A NCAC 02H .0805 (g) (1). D. Finding: The pH meter calibration does not bracket the range of samples being analyzed. Requirement: For routine work, use a pH meter accurate and reproducible to 0.1 pH unit with a range of 0 to 14, equipped with a temperature compensation device. Follow all manufacturers’ recommendations for the calibration of the meter each analysis day. The meter must be calibrated with at least two buffers. In addition to the calibration standards, the meter must be verified with a third calibration standard. The calibration and check standard buffer must bracket the range of the samples being analyzed. Ref: NC WW/GW LC Approved Procedure for Field Analysis of pH. Comment: Pretreatment effluent sample values were observed to sometimes exceed 10 S. U. (i.e., 10.39 and 10.54), which exceeds the highest calibration buffer. Recommendation: It is recommended that the laboratory calibrate its instrument with the 4.0, 7.0 and 10 buffers (or per manufacturer’s instructions) and analyze the 11.0 or 12.0 buffer as a check standard in order to bracket the range of the samples being analyzed. E. Finding: The laboratory is not analyzing a check buffer on each analysis day. Requirement: The meter must be calibrated with at least two buffers. In addition to the calibration standards, the meter must be verified with a third calibration standard. The calibration and check standard buffer must bracket the range of the samples being analyzed. The check standard buffer must read within a range of ± 0.1 pH units to be acceptable. Ref: NC WW/GW LC Approved Procedure for Field Analysis of pH. IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing field testing records and contract lab reports to semi-annual and daily Industrial User Pretreatment Permit (IUP) Reports submitted to the City of Reidsville Pretreatment Division. Data were reviewed for Envision Plastics (NPDES permit #NC0024881) and City of Reidsville Page 3 #5585 Envision Plastics (Industrial User Pretreatment Permit #0011) for May, June and July, 2012. No transcription errors were detected. It appears the laboratory is doing a good job of accurately transcribing data. 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. Report prepared by: Jeffrey R. Adams Date: August 28, 2012 Report reviewed by: Todd Crawford Date: August 31, 2012