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HomeMy WebLinkAbout#5479_09_2012_FINAL�@Al NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Charles Wakild, P. E. Governor Director October 30, 2012 5479 Mr. Joseph Cote, Jr Belmont Textile Machinery Company P.O. Box 568 Mount Holly, NC 28120 Dee Freeman Secretary SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Cote: Enclosed is a report for the inspection performed on September 26, 2012 by Jason Smith. 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 Certification Unit Supervisor Laboratory Section CC: Jason Smith Chet Whiting 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 One Internet: www.dwglab.org North . a.roli 2a An Equal Opportunity \ Affirmative Action Employer Naturally INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5479 Laboratory Name: Belmont Textile Machinery Company Inspection Type: Field Maintenance Inspector Name(s): Jason Smith Inspection Date: September 26, 2012 Date Report Completed: October 18, 2012 Date Forwarded to Reviewer: October 19, 2012 Reviewed by: Chet Whitintq Date Review Completed: October 19 2012 Cover Letter to use: ❑ Insp. Initial ❑ Insp. Reg. ❑ Insp. No Finding ❑ Insp. CP ® Corrected Unit Supervisor: Gary Francies Date Received: 10/22/2012 Date Forwarded to Linda: 10/30/2012 Date Mailed: l 13 1 11za LABORATORY NAME: NPDES PERMIT #: ADDRESS: CERTIFICATE #: DATE OF INSPECTION: TYPE OF INSPECTION: AUDITOR(S): LOCAL PERSON(S) CONTACTED: INTRODUCTION: On -Site Inspection Report Belmont Textile Machinery Company NCO023540 P.O. Box 568 Mount Holly, NC 28120 5479 September 26, 2012 Field Maintenance Jason Smith Joseph Cote, Jr. 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 lab has all the equipment_ necessary to perform the analyses. Proficiency Testing (PT) samples have been analyzed for all certified parameters for the 2012 proficiency testing calendar year and the graded results were acceptable. Contracted analyses are performed by K&W Laboratories (Certification #559).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. 1:I ��Tf1-��1 F1`��:7=fFY�C:��►�i t �rr�.�i�iri�i f ► i l�fi��\ FI �7 :7 =[K�7 ►r t►�� t� 1�7t� fir` �I Documentation Comment: The laboratory needed to increase the documentation of purchased materials and reagents, as well as documentation of standards and reagents prepared in the laboratory. The 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. 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 standards 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., preparation of Potassium Permanganate will be documented when made) was received by email on September 26, 2012. Laboratory personnel created a traceability log for purchased materials and reagents at the time of the inspection. No further response is necessary for this finding. Page 2 #5479 Belmont Textile Machinery Company Comment: Error corrections were not dated when performed. The Quality Assurance Policies for Field Laboratories document states: 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 chancre documented. All data and log entries must be written in indelible ink. Pencil entries are not acceptable. This requirement is a new policy that has been implemented by our program since the last inspection. Notification of acceptable corrective action (i.e., error corrections will be dated when performed) was received by email on September 26, 2012. No further response is necessary for this finding. Quality Control Comment: The auto-pipettor has not been calibrated. The Quality Assurance Policies for Field Laboratories document states: Mechanical volumetric liquid -dispensing devices (e.g., fixed and adjustable auto-pipettors, bottle -top dispensers, etc.) must be calibrated at least every twelve months and documented. Each liquid -dispensing device must meet the manufacturer's statement of accuracy. For variable volume devices used at more than one setting, check the accuracy at the maximum, middle and minimum values. Testing at more than three volumes is optional. When a device capable of variable settings is dedicated to dispense a single specific volume, calibration is required at that setting only. This requirement is a new policy that has been implemented by our program since the last inspection. Notification of acceptable corrective action (i.e., the auto-pipettor will be calibrated prior to being used) was received by email on September 26, 2012. No further response is necessary for this finding. Comment: The auto-pipettor is used to prepare the Total Residual Chlorine standards for verification of the instrument's internal curve and to prepare the Proficiency Testing sample for analysis. Proficiency Testing Comment: The preparation of Proficiency Testing (PT) samples was not documented. The Proficiency Testing Requirements, February 20, 2012, Revision 1.2. document states: PT samples received as ampules must be diluted according to the PT provider's instructions. The preparation of PT samples must be documented in a traceable log or other traceable format. The diluted PT sample becomes a routine environmental sample and is added to a routine sample batch for analysis. This requirement is a new policy that has been implemented by our program since the last inspection. Notification of acceptable corrective action (i.e., PT instructions will be signed and dated to document preparation) was received by email on September 26, 2012. No further response is necessary for this finding. Comment: PT samples were not analyzed in the same manner as environmental samples. A known sample was analyzed with the PT samples and multiple analyses were performed. The Quality Assurance Policies for Field Laboratories document states: The analysis of 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. This requirement is a new policy that has been implemented by our program since the last inspection. Notification of acceptable corrective action (i.e., PT will be analyzed in the same manner as environmental samples) was received by email on September 26, 2012. No further response is necessary for this finding. Comment: The laboratory was not documenting PT sample analyses in the same manner as environmental samples. The Proficiency Testing Requirements, February 20, 2012, Revision 1.2. document states: All PT sample analyses must be recorded in the daily analysis records as for any Page 3 #5479 Belmont Textile Machinery Company environmental sample. This serves as the permanent laboratory record. This requirement is a new policy that has been implemented by our program since the last inspection. During the inspection, laboratory personnel created an identical benchsheet to their normal benchsheet, except labeled for the PT, to be used for PT analysis documentation. No further response is necessary for this finding. Comment: Proper method codes were not reported with the PT results. The Proficiency Testing Requirements, February 20, 2012, Revision 1.2. document states: Laboratories must also be careful to designate the correct method code(s) being used for each PT sample result. To ensure that you are reporting the correct method, review your certificate attachment (i.e., certified parameter list). If you are using a method that is not listed on your certificate attachment (i.e., certified parameter list), please contact your auditor so that your certificate can be updated. The method must include the entire method reference as is written on your certificate attachment (i.e., certified parameter list). This requirement is a new policy that has been implemented by our program since the last inspection. Notification of acceptable corrective action (i.e., PT results will be reported with the correct method codes) was received by email on September 26, 2012. No further response is necessary for this finding. pH — Standard Methods 4500 H+ B Comment: Values were reported that exceed the method specified accuracy of 0.1 units. Standard Methods, 4500 H+ B-2000, (6) states: By careful use of a laboratory pH meter with good electrodes, a precision of ±0.02 unit and an accuracy of ±0.05 unit can be achieved. 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. The Discharge Monitoring Report form was edited during the inspection to round pH results to one decimal place. No further response is necessary for this finding. Temperature — Standard Methods 2550 B pH — Standard Methods 4500 H+ B Comment: Temperature and pH are analyzed at the time of collection, but the benchsheet indicated that they were analyzed later along with the Total Residual Chlorine sample. The North Carolina Administrative Code, 15A NCAC 2H .0805 (g) (1) states: Data pertinent to each analysis must be maintained for five years. Certified Data must consist of date collected, time collected, samples site, sample collector, and sample analysis time. The field benchsheets must provide a space for the signature of the analyst, and proper units of measure for all analyses. Laboratory personnel updated the benchsheet to state "pH and Temperature analyzed at time of sampling" during the inspection. No further response is necessary for this finding. IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing laboratory benchsheets and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data were reviewed for May, June, July, and August, 2012. The following errors were noted: Date Parameter Location Value on Benchsheet Value on DMR (*Contract Lab Data) 6/4/12 Total Residual Effluent 12,ug/L 15 mg/L Chlorine 6/12/12 Biochemical Effluent 4.2 mg/L * 2.4 mg/L Oxygen Demand Page 4 #5479 Belmont Textile Machinery Company 8/19/12 Total Residual Effluent No result 12,ug/L Chlorine 8/21/12 Total Residual Effluent 12,ug/L <10 /jg/L Chlorine 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 made available to the Regional Office. 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: Jason Smith Report reviewed by: Chet Whiting Date: October 18, 2012 Date: October 19, 2012