HomeMy WebLinkAbout#5477 - 10 - 2011 - FINALINSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5477
Laboratory Name:
M.B. Industries Inc. Wastewater Treatment Plant
Inspection Type:
Field Maintenance
Inspector Name(s):
Jason Smith
Inspection Date:
October 6, 2011
Date Report Completed:
October 17 2011
Date Forwarded to Reviewer: October 18, 2011
Reviewed bv:
Jeffrey R. Adams
Date Review Completed:
October 19, 2011
Cover Letter to use: _
Insp. Initial X Insp. Reg. _ Insp. No Finding _ Insp. CP _Corrected
Unit Supervisor:
Gary Francies
Date Received:
10/21/2011
Date Forwarded to Linda:
11/3/2011
Date Mailed:
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NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
November 4, 2011
5477
Mr. Wade Sanders
M.B. Industries, Inc. Wastewater Treatment Plant
P.O. Box 1118
Rosman, NC 28772
SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Sanders:
Dee Freeman
Secretary
Enclosed is a report for the inspection performed on October 6, 2011 by Jason Smith. 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. 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 me at 828-296-4677.
Sincerely,
Gary Francies
Unit Supervisor
Laboratory Section
CC: Jason Smith
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
Internet: www.dwglab.org
NorthiCarolina
Naturally
An Equal Opportunity \ Affirmative Action Employer Customer Service: 1-877.623-6748 www.neGvaterquality.org
LABORATORY NAME: M.B. Industries, Inc. Wastewater Treatment Plant
NPDES PERMIT #: NC0000311
ADDRESS: P.O. Box 1118
Rosman, NC 28772
CERTIFICATE #: 5477
DATE OF INSPECTION: October 6, 2011
TYPE OF INSPECTION: Field Maintenance
AUDITOR(S): Jason Smith
LOCAL PERSON(S) CONTACTED: Wade Sanders and Conrad Strafford
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This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for
the analysis of environmental samples.
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The facility has all the equipment necessary to perform the analyses. Proficiency testing samples have
been analyzed for all certified parameters for the 2011 proficiency testing calendar year and the graded
results were 100% acceptable. The requirements associated with Findings A, B, C, and F are new
policies that have been implemented by our program since the last inspection.
A. Finding: Error corrections in data transcription are not dated when corrections are made..
Requirement: 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. Ref: Quality Assurance Policies for Field
Laboratories.
B. Finding: The laboratory needs to increase the documentation of purchased materials and
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. A system (e.g., traceable identifiers) must be in place that links
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#5477 M.B. Industries, Inc. Wastewater Treatment Plant
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. Ref: Quality Assurance Policies for Field Laboratories.
C. Finding: Data that does not meet all quality control requirements is not qualified on the
Discharge Monitoring Report (DMR).
Requirement: When quality control (QC) failures occur, the laboratory must attempt to
determine the source of the problem and must apply corrective action. Part of the corrective
action is notification to the end user. If data qualifiers are used to qualify samples not meeting
QC requirements, the data may not be useable for the intended purposes. It is the responsibility
of the laboratory to provide the client or end -user of the data with sufficient information to
determine the usability of the qualified data. Where applicable, a notation must be made on the
DMR form, in the comment section or on a separate sheet attached to the DMR form, when any
required sample quality control does not meet specified criteria and another sample cannot be
obtained. Ref: Quality Assurance Policies for Field Laboratories.
pH — Standard methods, 18th Edition, 4500 H+ B
Temperature —Standard Methods, 18th Edition, 2550 B
D. Finding: The traceable thermometer was past its calibration date.
Requirement: NIST traceable thermometers used for temperature measurement must be
recalibrated in accordance with the manufacturer's recalibration date. If no recalibration date is
given, the NIST traceable thermometer must be recalibrated annually. Ref: Technical Assistance
for Field Analysis of Temperature and Technical Assistance for Field Analysis of pH. Please
submit a copy of the certification of the new traceable thermometer a copy of the
temperature sensor check with the reply to this report.
Comment: The traceable thermometer was due for calibration or replacement on October 1,
2010.
E. Finding: The pH meter is not calibrated on the days when analyses are performed.
Requirement: When only occasional pH measurements are made standardize instrument before
each measurement. Ref: Standard Methods, 18th Edition, 4500 H+ B. (4) (a).
Requirement: The meter must be calibrated prior to the analysis of samples. Ref: Technical
Assistance for Field Analysis of pH.
Comment: The laboratory began calibrating the instrument on Monday for process control
samples, but not recalibrating on Wednesday, which is when NPDES samples are analyzed. This
practice began when the primary analyst was out sick and was not corrected.
F. Finding: Proficiency Testing (PT) samples are not analyzed and documented in the same
manner as environmental samples.
IN
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#5477 M.B. Industries, Inc. Wastewater Treatment Plant
Requirement: The analysis of performance testing (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.
Ref: Quality Assurance Policies for Field Laboratories.
Comment: PT samples were analyzed multiple times and the results were not documented on
daily benchsheets as environmental samples are documented.
PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing field testing records and contract lab reports to Discharge
Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data were
reviewed for M.B. Industries (NPDES permit #NC0000311) Outfall 001, Outfall 003, Upstream, and
Downstream for January, March, and May, 2011. The following error was noted:
Date
Parameter
Location
Value on Contract
Value on DMR
Lab Report
1/4/2011
Chromium
Effluent
0.13 mg/L
0.13 pg/L
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 forwarded to the Regional Office.
Correcting the above -cited findings will help this lab to produce quality data and meet certification
requirements. The inspectors would like to thank the staff for its assistance during the inspection and
data review process. Please respond to all findings.
Report prepared by: Jason Smith
Report reviewed by: Jeffrey R. Adams
Date: October 17, 2011
Date: October 19, 2011