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HomeMy WebLinkAbout#140_02_2014_final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 140 Laboratory Name: International Paper - Riegelwood Mill Inspection Type: Industrial Maintenance Inspector Name(s): Todd Crawford, Gary Francies Inspection Date: February 27, 2014 Date Report Completed: March 25, 2014 Date Forwarded to Reviewer: March 25, 2014 Reviewed by: Jason Smith Date Review Completed: March 28, 2014 Cover Letter to use: Insp. Initial Insp. Reg. Insp. No Finding Insp. CP Corrected Unit Supervisor/Chemist III: Dana Satterwhite Date Received: 3/31/2014 Date Forwarded to Linda: 4/1/2014 Date Mailed: 4/2/2014 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: International Paper - Riegelwood Mill NPDES PERMIT #: NC0003298 ADDRESS: 865 John L. Riegel Road Riegelwood, NC 28456 CERTIFICATE #: 140 DATE OF INSPECTION: February 27, 2014 TYPE OF INSPECTION: Industrial Maintenance AUDITOR(S): Todd Crawford and Gary Francies LOCAL PERSON(S) CONTACTED: Ire Etheridge, Emily Henderson, Edward Kreul and Pat Soles 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 well organized. The facility has all the equipment necessary to perform the analyses. Proficiency Testing (PT) samples for the 2014 proficiency testing calendar year have not yet been analyzed. Results must be submitted to this office directly from the vendor by September 30, 2014. The laboratory is reminded that any time changes are made to laboratory operations; the laboratory must update the Quality Assurance (QA)/Standard Operating Procedures (SOP) document(s). Any changes made in response to the Findings, Recommendations or Comments listed in this report must be incorporated to insure the method is being performed as stated, references to methods are accurate, and the QA and/or SOP document(s) is in agreement with approved practice and regulatory requirements. In some instances, the laboratory may need to create a SOP to document how new functions or policy will be implemented. Contracted analyses are performed by Environmental Chemists, Inc. (Certification # 94), ALS/Columbia Analytical Services – WA (Certification # 605), ALS Environmental – Jacksonville (Certification # 527), ALS Laboratory Group, Houston (Certification # 624) and SGS North America, Inc. (Certification #481). III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation Comment: Instrument identifications of field meters used for pH and Dissolved Oxygen (DO) were not documented on the field check sheets. The NC WW/GW LC Approved Procedure for the Analysis of pH and the NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen documents state: Page 2 #140 International Paper - Riegelwood Mill The following must be documented in indelible ink whenever sample analysis is performed: Instrument identification. This requirement is a new policy that has been implemented by our program since the last inspection. Notification of acceptable corrective action (i.e., revised field check sheets showing meter identifications) was received by email on 3/25/2014. No further response is necessary for this finding. Comment: The laboratory was not adequately documenting the traceability of purchased materials and reagents. NC WW/GW LC Policy 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 (where specified). 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 primary standards, chemicals, reagents, and materials used for a period of five years. Consumable materials such as pH buffers, lots of pre-made standards and/or media, solids and bacteria filters, etc. 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., a letter stating that a chemical receipt/traceability log, following the template that was provided during the audit, had been put into use) was received by email on 3/7/2014. No further response is necessary for this finding. Comment: The BOD benchsheet was lacking concentration units for pH and DO meter calibrations. The field parameters check sheet was lacking concentration units for pH. The North Carolina Administrative Code, 15A NCAC 2H .0805 (a) (7) (H) states: All laboratories must use printed laboratory bench worksheets that include a space to enter the signature or initials of the analyst, date of analyses, sample identification, volume of sample analyzed, value from the measurement system, factor and final value to be reported and each item must be recorded each time samples are analyzed. Notifications of acceptable corrective actions (i.e., revised BOD benchsheet and revised field check sheet showing all concentration units) were received by email on 3/21/2014. No further response is necessary for this finding. Residue, Suspended – Standard Methods, 2540 D-1997 Comment: North Carolina allows for an annual drying study in lieu of the method requirement to “Repeat the cycle of drying, cooling, desiccating, and weighing until a constant weight is obtained or until the weight change is less than 4% of the previous weight or 0.5 mg, whichever is less”. A random full set of samples should be used for the drying study. The repeated drying time in the oven should be at least 1 hour long. The time used for the annual drying study is the minimum time that samples are to be dried until a new drying study is performed. BOD – Standard Methods, 5210 B-2001 Comment: An air stone is not used when making the seed solution. Instead of “stirring”, the manufacturer’s instructions indicate the seed should be “aerated” during preparation. The extra oxygen appears to result in a more viable seeding material. This is accomplished by bubbling air through the mixture while stirring. (A common aquarium air pump and aeration stone may be used). Since the current lot of seed material is performing acceptably it is not recommended that the laboratory change its current procedure. But it is recommended that if future seed solutions do not consistently yi eld acceptable GGA results, that aeration during seed solution preparation be implemented. Comment: A minimum of three (3) dilutions was not being analyzed. Standard Methods 5210 B-2001 (5) (c) states: “Using the dilution waster prepared as in ¶ a above, make at least three dilutions of prepared samples estimated to produce a residual DO of at least 1.0 mg/L and a DO uptake of at least 2.0 mg/L after a 5-d incubation”. Notifications of acceptable corrective action (i.e., a letter stating that the SOP had been revised to require three dilutions and a revised benchsheet with space for three Page 3 #140 International Paper - Riegelwood Mill dilutions) were received by email on 3/7/14 and 3/21/14, respectively. No further response is necessary for this finding. Comment: The dilution water blank acceptance criterion was based on a depletion of no more than 0.2 mg/L, which was lacking the required degree of sensitivity. Standard Methods 5210 B-2001 (5) (a) states: “If the dilution water blanks show a DO depletion greater than 0.20 mg/L, obtain a satisfacto ry water by improving the purification or use water from another source. Do not add oxidizing agents or expose to ultraviolet light in attempts to bring the dilution blank into range”. Notifications of acceptable corrective action (i.e., a letter stating that the SOP and Corrective Action Form were revised to show a 0.20 mg/L acceptance criterion and a revised benchsheet showing the 0.20 mg/L acceptance criterion) were received by email on 3/7/14 and 3/21/14, respectively. No further response is necessary for this finding. Recommendation: It is recommended that a separate bottle of dilution water be used for checking DO meter calibration drift in order to reduce the risk of contaminating the dilution water sample that is incubated. Recommendation: It is recommended that a “seeded blank” be analyzed as QC check of analyst technique and homogeneity of seeding material. pH – Standard Methods, 4500 H+B-2000 Comment: The pH meter was not being consistently calibrated each day of use. The NC WW/GW LC Approved Procedure for the Analysis of pH document states: Instruments are to be calibrated according to the manufacturer’s calibration procedure prior to analysis of samples each day compliance monitoring is performed. Notification of acceptable corrective action (i.e., a letter stating that all effected SOPs have been updated to include daily pH calibrations and copy of the revised pH calibration worksheet) were received by email on 3/7/14 and 3/21/14, respectively. No further response is necessary for this finding. IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing field testing records, laboratory benchsheets and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Resources. Data were reviewed for NPDES permit # NC0003298 for October, 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. Implementing the recommendations will further improve the quality of the data. The inspector(s) would like to thank the staff for its assistance during the inspection and data review process. No response is required. Report prepared by: Todd Crawford Date: March 25, 2014 Report reviewed by: Jason Smith Date: March 28, 2014