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HomeMy WebLinkAbout#5105_01_2014_FINALFebruary 11, 2014 5105 Ms. Hope Walters DuPont Company - Fayetteville Works 22828 NC Hwy. 87 W Fayetteville, NC 28306 SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Ms. Walters: Enclosed is a report for the inspection performed on January 28, 2014 by Nick Jones. 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 Technical Assistance/Compliance Specialist Laboratory Section Enclosure cc: master file Nick Jones DBNR DWR WQP 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: 919-733-39081,, FAX: 919 733-6241 internet: www,dw glab.org An Equal Opporfunliy ` Arrirmanve Action Employer INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5105 Laboratory Name: DuPont Company - Fayetteville Works Inspection Type: Field Maintenance Inspector Name(s): Nick Jones Inspection Date: January 28, 2014 Date Report Completed: January 29, 2014 Date Forwarded to Reviewer: January 29, 2014 Reviewed by: Chet Whiting Date Review Completed: January 31, 2014 Cover Letter to use: ❑ Insp. Initial ❑ Insp. Reg. ❑ Insp. No Finding ❑ Insp. CP ❑ Corrected Unit Supervisor/Chemist III: Gary Francies Date Received: 1/31/2014 Date Forwarded to Linda: 2/10/2014 �)✓ Date Mailed: a) I l I A LABORATORY NAME: NPDES PERMIT #: ADDRESS: CERTIFICATE #: DATE OF INSPECTION: TYPE OF INSPECTION: AUDITOR(S): LOCAL PERSON(S) CONTACTED: INTRODUCTION: On -Site Inspection Report DuPont Company - Fayetteville Works NC0003573 22828 NC Hwy. 87 W Fayetteville, NC 28306 5105 January 28, 2014 Industrial Maintenance Nick Jones Hope Walters and Jamie Lewis 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. 11. GENERAL COMMENTS: The laboratory was clean and well organized. The facility has all the equipment necessary to perform the analyses. Laboratory personnel communicate well with sample collectors and coordinate sample analyses effectively to manage workload and holding times. Contracted analyses are performed by TBL Environmental Laboratory, Inc. (Certification #37). 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. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Quality Control Comment: The laboratory needs to increase the documentation of purchased materials and reagents, as well as documentation of standards and reagents prepared in the laboratory. The NC WW/GW LC 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. 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 Page 2 #5105 - DuPont Company - Fayetteville Works for a period of five years. Consumable materials such as pH buffers and lots of pre -made standards are included in this requirement. Demonstration of acceptable corrective action (i.e., an updated traceability log which includes Date Received, Date Opened, Lot Number, and Expiration Date) was received by email on 1/28/2014. No further response is necessary for this finding. Documentation Comment: The benchsheet used by the laboratory did not contain all of the necessary labeling information. No units of measure (S.U.) are associated with the pH meter calibration results on the pH benchsheet. The Facility Name and instrument ID were not documented on the pH benchsheet. The NC WW/GW LC Approved Procedure for the Analysis of pH document states: The following must be documented in indelible ink whenever sample analysis is performed. 3. Sample site including facility name and location, ID, etc. 12. Instrument identification. The North Carolina Administrative Code, 15A NCAC 2H .0805 (g) (1) states: The field bench sheets must provide a space for the signature or initials of the analyst, and proper units of measure for all analyses. Demonstration of acceptable corrective action (i.e., an updated benchsheet which includes proper units of measure for pH calibration, facility and instrument ID for pH) was received by email on 1/28/2014. No further response is necessary for this finding. Comment: The benchsheet used by the laboratory did not contain all of the necessary labeling information. The Facility Name and instrument ID were not documented on the Temperature benchsheet. The NC WW/GW LC Approved Procedure for the Analysis of Temperature document states: The following must be documented in indelible ink whenever sample analysis is performed. 3. Sample site including facility name and location, ID, etc. 9. Thermometer/instrument identification. Demonstration of acceptable corrective action (i.e., an updated benchsheet which includes facility name and instrument ID for Temperature) was received by email on 1/28/2014. No further response is necessary for this finding. Proficiency Testing Comment: The laboratory is not documenting Proficiency Testing (PT) sample analyses in the same manner as environmental samples. The NC WW/GW LC Proficiency Testing Requirements document states: All PT sample analyses must be recorded in the daily analysis records as for any environmental sample. This serves as the permanent laboratory record. Notification of acceptable corrective action (i.e., a statement that all PT sample analyses will be recorded in the daily analysis records as for any environmental sample.) was received by e-mail on 1/29/2014. No further response is necessary for this finding. PH — SM 4500 H+B-2000 Comment: Values were reported that exceed the method specified accuracy of 0.1 units. Standard Methods, 4500 H+ B-2000, (6) states in part: 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. Notification of acceptable corrective action (i.e., a statement that pH results would be reported to 0.1 units.) was received by e-mail on 1/29/2014. No further response is necessary for this finding. IV. Page 3 #5105 - DuPont Company - Fayetteville Works 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 Resources. Data were reviewed for DuPont Company - Fayetteville Works (NPDES permit # NC0003573 for August, September and October of 2013. No transcription errors were detected. The facility appears to be doing a good job of accurately transcribing data. 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: Nick Jones Report reviewed by: Chet Whiting Date: January 28, 2014 Date: January 30, 2014