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HomeMy WebLinkAbout#412_ 2011 INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 412 Laboratory Name: Smithfield Packing Company WWTP Lab Inspection Type: Industrial Maintenance Inspector Name(s): Tonja Springer, Gary Francies, and David Livingston Inspection Date: June 21, 2011 Date Report Completed: July 13, 2011 Date Forwarded to Reviewer: July 15, 2011 Reviewed by: Jason Smith Date Review Completed: July 22, 2011 Cover Letter to use: Insp. Initial __Insp. Reg. Insp. No Finding Insp. CP X Corrected Unit Supervisor: Dana Satterwhite Date Received: July 26, 2011 Date Forwarded to Linda: August 1, 2011 Date Mailed: August 1, 2011 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Smithfield Packing Company WWTP Lab NPDES PERMIT #: NC0078344 ADDRESS: P.O. Box 189 Tar Heel, NC 28392 CERTIFICATE #: 412 DATE OF INSPECTION: June 21, 2011 TYPE OF INSPECTION: Industrial Maintenance AUDITOR(S): Tonja Springer, Gary Francies, David Livingston LOCAL PERSON(S) CONTACTED: Xiaolin Chen I. INTRODUCTION: This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for the analysis of environmental samples. II. GENERAL COMMENTS: The inspectors would like to commend the laboratory for staying current with changes in laboratory certification program requirements by visiting the NC Wastewater/Groundwater Laboratory Certification website and proactively implementing new requirements (such as reporting limit changes for Total Suspended Solids and matrix spiking) between inspections. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: General Laboratory Comment: Uncertified data (i.e., process control data) was documented with the certified data and not clearly identified. The North Carolina Administrative Code, 15A NCAC 2H .0805 (e) (3) states: All uncertified data must be clearly documented as such on the benchsheet and on the final report. Demonstration of acceptable corrective action (i.e., an updated benchsheet) was received by electronic mail on 6/29/2011. No further response is necessary for this finding. Comment: The autoclave maximum pressure and the material autoclaved are not being documented on the autoclave logbook. The North Carolina Administrative Code, 15A NCAC 2H .0805 (a) (7) (J) states: Each day an incubator, oven, water bath or refrigerator is used, the temperature must be checked, recorded, and initialed. During each use the autoclave maximum temperature and pressure must be checked, recorded, and initialed. Demonstration of acceptable corrective action (i.e., an updated logbook sheet with spaces added to record maximum pressure and the material autoclaved) was received by electronic mail on 6/29/2011. No further response is necessary for this finding. Page 2 #412 Smithfield Packing Company WWTP Lab Biochemical Oxygen Demand – Standard Methods, 19th Edition, 5210 B Comment: The initial pH of samples is not being documented. The North Carolina Administrative Code, 15A NCAC 2H .0805 (a) (7) states: Each laboratory shall develop and maintain a document outlining the analytical quality control practices used for the parameters included in their certification. Supporting records shall be maintained as evidence that these practices are being effectively carried out. Demonstration of acceptable corrective action (i.e., an updated copy of the page in the Standard Operating Procedures (SOP)) was received by electronic mail on 6/29/2011. No further response is necessary for this finding. Comment: Total residual chlorine strips are being used to test for chlorine. North Carolina Wastewater/Groundwater Laboratory Certification Policy states: It is acceptable to screen samples with DPD powder for the presence of Total Residual Chlorine (use pillows appropriate for the volume of sample tested). Generally total residual chlorine test strips are not adequate; however, these may be used for samples where interference with DPD precludes their use. Notification of acceptable corrective action (i.e., the laboratory stated they will be using the DPD method to check the final effluent for total residual) chlorine was received by electronic mail on 6/29/2011. No further response is necessary for this finding. Comment: The Dissolved Oxygen (DO) meter is not checked for drift at the end of the analytical series. North Carolina Wastewater/Groundwater Laboratory Certification Policy based upon Standard Methods, 21st Edition, 5210 B. (5) (g) states: If the membrane electrode method is used, take care to eliminate drift in calibration between initial and final DO readings. Demonstration of acceptable corrective action (i.e., an updated benchsheet along with a statement regarding a drift check had been added at end of each test) was received by electronic mail on 6/29/2011. No further response is necessary for this finding. Fecal Coliform – Standard Methods, 19th Edition, 9222 D (MF) Comment: The laboratory needed to increase the traceability of the consumable materials to the analytical batches. North Carolina Wastewater/Groundwater Laboratory Certification 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. Notification of acceptable corrective action (i.e., the laboratory stated, for traceability purposes during consumable studies for fecal, they will be tracking the lot numbers of consumable items used for final effluent analysis) was received by electronic mail on 6/29/2011. No further response is necessary for this finding. Comment: The chlorine removal check is not being documented. The North Carolina Administrative Code, 15A NCAC 2H .0805 (a) (7) (M) states: A record of date collected, time collected, sample collector, and the use of proper preservatives must be maintained. Demonstration of acceptable corrective action (i.e., an updated benchsheet along with a statement that the chlorine removal check is being documented) was received by electronic mail on 6/29/2011. No further response is necessary for this finding. Page 3 #412 Smithfield Packing Company WWTP Lab Comment: Duplicate acceptance criteria are not documented in the SOP. The North Carolina Administrative Code, 15A NCAC 2H .0805 (a) (7) states: Each laboratory shall develop and maintain a document outlining the analytical quality control practices used for the parameters included in their certification. Supporting records shall be maintained as evidence that these practices are being effectively carried out. Demonstration of acceptable corrective action (i.e., an updated copy of the page in the SOP which describes a two tiered system for establishing duplicate criteria) was received by electronic mail on 6/29/2011. No further response is necessary for this finding. Comment: Ultraviolet sterilization lamps are not tested quarterly. Standard Methods, 19th Edition, 9020 B. (2) (m) states: Disconnect unit monthly and clean lamps by wiping with a soft cloth moistened with ethanol. Test lamps quarterly with UV light meter and replace if they emit less than 70% of initial output or if plate count agar spread plates containing 200 to 250 microorganisms, exposed to the light for 2 min, do not show a count reduction of 99%. Notification of acceptable corrective action (i.e., a statement regarding the UV sterilizer will no longer be used, instead the lab will use the autoclave for disinfection of all fecal test apparatus) was received on 6/29/2011 by electronic mail. No further response is necessary for this finding. Comment: Coliform density was not calculated correctly on a sample that had not yet been reported. The sample was analyzed on 6/3/2011. The calculated result was 57 colonies per 100 mL. From the Fecal Coliform Reporting document, the lab was using Rule #2 (b) which states: Total the counts of all filters and report as number per 100 mL. In this instance, the laboratory should have used Rule #1 which states: If more than one filter has a count in the acceptable range, calculate the values in counts/100 mL and average. This was corrected at the time of the inspection. The corrected result was 62.5 colonies per 100 mL. No further response is necessary for this finding. Recommendation: It was recommended that the lab use glass, class A pipettes for measuring sample volumes of 10 mL or less instead of the graduated cylinders. An electronic mail was received on 6/29/2011 indicating that the laboratory will begin using pipettes for sample volumes 10 mL or less. Recommendation: It was recommended that the lab add columns to the benchsheet for the calculated results and final reported results. An updated benchsheet with these recommendations implemented was received by electronic mail on 6/29/2011. Total Suspended Residue – Standard Methods, 19th Edition, 2540 D Comment: Filters are not weighed to a constant weight after initial washing nor is a dry filter blank analyzed with each set of samples. North Carolina Wastewater/Groundwater Laboratory Certification Policy, based upon Standard Methods, 20th Edition, 2540 D. (3) (a) states: If pre-prepared filters are not used, the method requires that filters must be weighed to a constant weight after washing. In lieu of this process, it is acceptable to analyze a single daily dry filter blank (i.e., no additional rinsing during the analysis). The acceptance criterion for the blank is a weight change of less than 4% of the filter’s initial weight or 0.5 mg, whichever is less. This requirement is a new policy that has been implemented by our program since the last inspection. Demonstration of acceptable corrective action (i.e., an updated benchsheet indicating that a dry blank is being analyzed) was received by electroinc mail on 6/29/2011. No further response is necessary for this finding. Settleable Residue – Standard Methods, 19th Edition, 2540 F Comment: The sample volume is not documented. 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 must be recorded each time samples are analyzed. Demonstration of acceptable corrective Page 4 #412 Smithfield Packing Company WWTP Lab action (i.e., an updated benchsheet) was received by electronic mail on 6/29/2011. No further response is necessary for this finding. Total Kjeldahl Nitrogen – Standard Methods, 19th Edition, 4500 NH3 D Comment: Laboratory reagent blanks exceed 50% of the reporting limit. North Carolina Wastewater/Groundwater Laboratory Certification Policy states: For analyses requiring a calibration curve, the concentration of method and reagent blanks must not exceed 50% of the reporting limit, unless otherwise specified by the reference method. This requirement is a new policy that has been implemented by our program since the last inspection. Demonstration of acceptable corrective action (i.e., an updated benchsheet) was received by electronic mail on 6/29/2011. 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 January and April 2011. No transcription errors were detected. The facility appears to be doing a good job of accurately transcribing data. V. CONCLUSIONS: All findings noted during this 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: Tonja Springer Date: July 13, 2011 Report reviewed by: Jason Smith Date: July 22, 2011