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Home My WebLink About#5618 12-Final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: #5618 Laboratory Name: Coty US, LLC Inspection Type: Field Initial Inspector Name(s): Jeffrey R. Adams Inspection Date: August 16, 2012 Date Report Completed: August 28, 2012 Date Forwarded to Reviewer: August 28, 2012 Reviewed by: Chet Whiting Date Review Completed: September 5, 2012 Cover Letter to use: X Insp. Initial Insp. Reg. Insp. No Finding Insp. CP __ Corrected Unit Supervisor: Dana Satterwhite Date Received: September 5, 2012 Date Forwarded to Linda: October 5, 2012 Date Mailed: October 8, 2012 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Coty US, LLC NPDES PERMIT #: NCG500182; NCG060000 ADDRESS: 1400 Broadway Road Sanford, NC, 27332 CERTIFICATE #: 5618 DATE OF INSPECTION: August 16, 2012 TYPE OF INSPECTION: Field Municipal Initial AUDITOR(S): Jeffrey R. Adams LOCAL PERSON(S) CONTACTED: David Vann and Neal Cutler 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. The laboratory is currently analyzing samples only for pH and Temperature for pretreatment and stormwater discharge semi-annually monitoring. However, some quality control procedures need to be implemented. This facility is reporting data under the City of Sanford’s pre-treatment program. The laboratory was given a packet containing North Carolina Laboratory Certification quality control policies and approved procedures for field testing during the inspection. Contracted analyses are performed by Prism Labs (Certification #402), Microbac Labs (Certification #11) and Cameron Testing (Certification #654). 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 Page 2 #5618 Coty US, LLC a period of five years. Consumable materials such as pH buffers and lots of pre-made 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. Comment: There was no supporting documentation of the PT analyses. Only a copy of the electronic data submittal to the PT vendor was retained. 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). Temperature – Standard Methods, 18th Edition, 2550 B D. Finding: The laboratory is not checking the temperature sensor on the pH meter annually against a National Institute of Standards and Technology (NIST) traceable thermometer and posting corrections on meter. 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 1ºC 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: North Carolina Wastewater/Groundwater Laboratory Certification Approved Procedure for Field Analysis of Temperature. Please submit a copy of the sensor checks with the response to this report. IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing field testing records and contract lab reports to semi-annual Industrial Pretreatment Program Self Monitoring Reports submitted to the City of Sanford Pretreatment Division and Stormwater Discharge Outfall (SDO) reports to the NC Division of Water Quality. Data were reviewed for Coty US, LLC (NPDES permit #NCG500182) City of Sanford (Industrial Pretreatment Permit #000010) dated February 9, 2012 and August 10, 2012 and to the NC Division of Water Quality (NPDES permit #NCG060012) dated April 18, 2011, December 7, 2011 and February 3, 2012. No transcription errors were detected. It appears the laboratory is doing a good job of accurately transcribing data. Page 3 #5618 Coty US, LLC 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: Jeffrey R. Adams Date: August 28, 2012 Report reviewed by: Chet Whiting Date: September 5, 2012