#198 - 12 - 2011 - FINAL

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To be attached to all inspection reports in-house only.
Laboratory Cert. #: 198
Laboratory Name: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Inspection Type: Municipal Maintenance
Inspector Name(s):
Inspection Date:
Date Report Completed:
Date Forwarded to Reviewer:
Reviewed by:
Date Review Completed:
Jason Smith
December 8 & 9, 2011
February 1, 2012
February 1, 2012
Todd Crawford
February 1, 2012
Cover Letter to use: _ Insp. Initial Insp. Reg. _ Insp. No Finding e Insp. CP X Corrected
Unit Supervisor:
Date Received:
Date Forwarded to Linda:
Date Mailed:
Gary Francies
February 1, 2012
2/28/2012
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NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue
Governor
198
Mr. John Pryately
Blue Ridge Paper Products Inc.
dba Evergreen Packaging
PO Box 4000
Canton, NC 28716
Charles Wakild, P. E.
Director
February 28, 2012
Dee Freeman
Secretary
SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Prately:
Enclosed is a report for the inspection performed on December 8 and 9, 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,
COY 1-'4�
Gary Francies
Certification Unit Supervisor
Laboratory Section
CC: Master File
DENR DWO 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: [phone]FAX: [phone]
Internet: www.dwglab.org
One
NofthCarolina
Naturally ,
An Equal Opportunity\Affirmative Action Employer

LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
I`11111 ZOI11� O CeP►
Blue Ridge Paper Products Inc. dba Evergreen Packaging
NC0000272
PO Box 4000
Canton, NC 28716
198
December 8 and 9, 2011
Industrial Maintenance
Jason Smith
John Pryately
This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for
the analysis of environmental samples.
The laboratory was well organized and has all the equipment necessary to perform the analyses. The
benchsheets are very well designed to present all of the data in a well organized and easy to follow
format. The staff does a good job of managing analyses performed on different shifts and at multiple
sampling locations (i.e., seven stream sampling points in addition to the treatment plant sampling).
The laboratory expressed an interest in obtaining certification for Biochemical Oxygen Demand by
Luminescence Dissolved Oxygen (LDO). Since this is a different technology than the membrane
electrode, an acceptable Proficiency T esting result performed with the LDO meter must be submitted
prior to obtaining certification.
Documentation
Recommendation: It was recommended that the laboratory document the time of receipt of river
samples. An email dated December 29, 2011 indicated that this recommendation has now been
implemented.
Comment: Temperature corrections were not posted on the meters and thermometers. North Carolina
Wastewater/Groundwater Laboratory Certification Policy states in part: Also document any correction
that applies (even if zero) on both the thermometer/meter and on a separate sheet to be filed.
Notification of acceptable corrective action (i.e., the temperature corrections are now posted on all meters
and thermometers) was received by email on December 29, 2011. No further response is necessary
for this finding.

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#198 Blue Ridge Paper Products Inc. dba Evergreen Packaging
Comment: The system of traceability needed improvements. The reagent preparation procedures were
not clearly documented and the date that items were put into use was not documented. North Carolina
Wastewater/Groundwater laboratory 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., all of the required changes that
were discussed during the inspection were made) was received by email on December 29, 2011. No
further response is necessary for this finding.
Quality Control
Comment: The bottle top dispensers have not been calibrated. North Carolina Wastewater/Groundwater
Laboratory Certification Policy states: Mechanical volumetric liquid -dispensing devices (e.g., fixed and
adjustable auto-pipettors, bottle -top dispensers, etc.) must be calibrated at least twice per year,
approximately six months apart. 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 bottle top dispensers were
calibrated on January 4, 2012 and will be calibrated at the required interval in the future) was received by
email on December 29, 2011. No further response is necessary for this finding.
Recommendation: It was recommended that the calibration times of the pH, Dissolved Oxygen (DO),
and Conductivity meters be documented. An email dated December 29, 2011 indicated that this
recommendation has now been implemented.
Comment: The collection and analysis times were not clearly documented. Only "time" was recorded with
no indication that sample analysis was performed immediately. The North Carolina Administrative Code,
15A NCAC 2H .0805 (a) (7) (M) states: A record of date collected, time collected, sample collector, and
use of proper preservatives must be maintained. Each sample must clearly indicate the State of North
Carolina collection site on all record transcriptions. The North Carolina Wastewater/Groundwater
Laboratory Certification memorandum dated June 20, 2007 titled "Required Documentation for Sampling
Preservation and Hold Time" states: The time elapsed between sampling and analysis must be
documented to determine if hold times are met. Notification of acceptable corrective action (i.e., the
benchsheet was updated to collection/analysis time) was received by letter on January 30, 2012. No
further response is necessary for this finding.
Conductivity — Standard Methods, 201h Edition, 2510 B
Comment: Units of measure for conductivity were not documented properly. 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

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#198 Blue Ridge Paper Products Inc. dba Evergreen Packaging
value to be reported and each item must be recorded each time samples are analyzed. The date and
time BOD and coliform samples are removed from the incubator must be included on the laboratory
worksheet. Demonstration of acceptable corrective action (i.e., submission of benchsheets with proper
units of measure documented) was received by email on December 29, 2011. No further response is
necessary for this finding.
Comment: The Automatic Temperature Compensator (ATC) verification was not performed properly.
The lowest temperature verified (8 °C) did not bracket the temperatures of the samples and the obtained
values of the standard at each temperature were not documented. North Carolina Wastewater/
Groundwater Laboratory Certification Policy states: The internal ATC must be verified every 12 months
and the process documented. The ATC must be verified by analyzing a standard at 25°C (the
temperature that conductivity values are compensated to) and a temperature(s) that brackets the
temperature ranges of the samples to be analyzed. As the temperature increases or decreases, the value
of the conductivity standard must be within ± 10% of the true value of the standard. Demonstration of
acceptable corrective action (i.e., verification down to 2 °C and recording the obtained values of the
standard) was performed at the time of the inspection. No further response is necessary for this
finding.
Comment: The check standard analyzed was not always within ± 0.1 SU. A two point calibration is
performed, followed by analyzing two check standards, the 7 SU buffer and one buffer outside of the
calibration range (either 4 or 10 SU depending on the calibration). The check buffer outside of the
calibration range was occasionally unacceptable, but the 7 SU buffer was the only one that was
evaluated. Standard Methods, 20th Edition, 4500 H+ B. (2) and (4) (a) state: For routine work, use a pH
meter accurate and reproducible to 0.1 pH units with a range of 0 to 14 and equipped with a
temperature compensation adjustment. The meter must be calibrated with at least two buffers that
bracket the range of the samples to be analyzed. After calibration, analyze a third buffer below pH 10,
approximately three pH units different from the second. The reading should be within 0.1 units of true
value. If the meter response shows a difference greater than 0.1 pH unit from expected value, look for
trouble with the electrodes or potentiometer. Notification of acceptable corrective action (i.e., 6 and 8 SU
buffers, which provide acceptable results due to being closer to the calibration points while still bracketing
the sample results, were put into use on February 1, 2012 and all check standards will be evaluated for
acceptance) was received by email on December 29, 2011 and by a letter received on January 30,
2012. No further response is necessary for this finding.
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Comment: The laboratory was not reporting all of the data for the effluent color samples. The North
Carolina Administrative Code, 15A NCAC 02B .0506 (3) (J) states: "The results of all tests on the
characteristics of the effluent, including but not limited to NPDES Permit Monitoring Requirements, shall
be reported on monthly report forms." The samples were analyzed in duplicate and averaged during each
of two shifts and the lowest obtained averaged value was reported. The laboratory did this believing that
the differences in the results were due to turbidity interference caused by colloidal solids. The colloidal
solids are sometimes visible in the first analyses and then disappear during refrigeration prior to the
second analysis. At other times the colloidal solids are not visible until the sample is stored in the
refrigerator prior to the second analysis. The method states that "even a slight turbidity causes the
measured color to be noticeably higher than the true color." For most samples, the method required
filtration with a 0.8 micron filter is sufficient to remove turbidity. After consulting with both EPA Region IV
and National Council for Air and Stream Improvement (NCASI), it appears the colloidal solids may be an
interference in obtaining the true color concentration. The laboratory is currently compiling data to
demonstrate the effect of the colloidal solids and turbidity on the color concentration of the sample. A
meeting will be scheduled in March 2012 to evaluate the data and discuss possible method modifications.

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#198 Blue Ridge Paper Products Inc. dba Evergreen Packaging
To ensure Clean Water Act compliance the laboratory may need to request approval for any proposed
method modification from EPA Region IV. Until this issue is resolved, the laboratory will average all
effluent color results for reporting on the Discharge Monitoring Report in order to comply with the above
cited Rule.
Comment: For stream samples, the Calibration Verification Standard (CVS) analyzed at the end of the
sample group was not mid -range (100 color units for a curve that goes up to 500 color units). North
Carolina Wastewater/Groundwater Laboratory Certification Policy based upon Standard Methods, 20th
Edition, 1020 B. (10) (c), 3020 B. (2) (b), and 4020 B. (2) states: The calibration blank and CVS (mid-
range) must be analyzed initially (i.e., prior to sample analysis), after every tenth sample and at the end of
each sample group to check for carry over and calibration drift. If either fall outside established quality
control acceptance criteria, corrective action must be taken (e.g., repeating sample determinations since
the last acceptable calibration -verification, repeating the initial calibration, etc.). 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 concentration of the CVS at the end of stream sample groups has been
changed to 250 color units) was received by email on December 29, 2011. No further response is
necessary for this finding.
Comment: For effluent samples, a blank and CVS were not analyzed at the end of the sample group.
North Carolina Wastewater/ Groundwater Laboratory Certification Policy based upon Standard Methods,
201h Edition, 1020 B. (10) (c), 3020 B. (2) (b), and 4020 B. (2) states: The calibration blank and CVS (mid-
range) must be analyzed initially (i.e., prior to sample analysis), after every tenth sample and at the end of
each sample group to check for carry over and calibration drift. If either fall outside established quality
control acceptance criteria, corrective action must be taken (e.g., repeating sample determinations since
the last acceptable calibration verification, repeating the initial calibration, etc.). 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 blank and CVS are now analyzed at the end of each effluent sample group) was
received by email on December 29, 2011. No further response is necessary for this finding.
Recommendation: The laboratory was using a blank acceptance criterion that was more restrictive than
required by the method. It was recommended that the laboratory use the method defined criterion of a
weight change of less than 4% of the filter's initial weight or 0.5 mg, whichever is less. An email dated
December 29, 2011 indicated that this recommendation has now been implemented.
Comment: Filters were not weighed to a constant weight after initial washing nor was 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. Repeat
cycle of drying, cooling, desiccating, and weighing until a constant weight is obtained or until weight
change is less than 4% of the previous weighing or 0.5 mg, whichever is less. In lieu of this process, it
is acceptable to analyze a single daily dry filter blank to fulfill the method requirement of drying all filters
to a constant weight prior to analysis. This is performed by washing all filters as required by the
method, then drying and desiccating them. The process of repeatedly heating, cooling, desiccating,
and weighing until a constant weight is documented is not required. Instead, a single dry blank filter
(i.e., no additional rinsing during the analysis) is analyzed. 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. Notification of
acceptable corrective action (i.e., a dry filter blank is analyzed with each sample group) was received by
email on December 29, 2011. No further response is necessary for this finding.

In
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#198 Blue Ridge Paper Products Inc. dba Evergreen Packaging
Ammonia Nitrogen — Standard Methods, 201h Edition, 4500 NH3 D
Comment: The laboratory was not performing matrix spike analyses. North Carolina Wastewater/
Groundwater Laboratory Certification Policy states in part: Unless the referenced method states a greater
frequency, spike 5% of samples on a monthly basis. Laboratories analyzing less than 20 samples per
month must analyze at least one matrix spike each month samples are analyzed. This requirement is a
new policy that has been implemented by our program since the last inspection. Notification of
acceptable corrective action (i.e., an amendment to drop certification for Ammonia) was received on
January 30, 2012. This change was made effective February 1, 2012 and the laboratory will be sending
Ammonia samples to their contract lab for analysis. No further response is necessary for this
finding.
Recommendation: The laboratory was checking for drift by documenting the percent saturation of the
probe in a partially filled bottle. During the inspection, it was recommended that the drift check be
performed by analyzing the Dissolved Oxygen of a full bottle of dilution water. An email dated December
29, 2011 indicated that this recommendation has now been implemented.
Comment: The laboratory elevated the reporting limit when samples did not meet the 2.0 mg/L Dissolved
Oxygen depletion requirement. The Sample Calculations and Reporting document states: North Carolina
Wastewater/Groundwater Laboratory Certification Policy prohibits raising the (PQL) reporting limit
because the "use 2 rule" was not met. Instead the value obtained is reported and flagged. This policy is
designed to prevent labs from artificially raising the PQL by setting "too low" dilutions and not
demonstrating permit compliance. 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 results will be
reported down to 2.0 mg/L and samples that do not deplete 2 mg/L of DO will be flagged) was received
by email on December 29, 2011. No further response is necessary for this finding.
The paper trail consisted of comparing laboratory benchsheets, field testing records, and contract lab
reports to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water
Q 6Aality. vats ° ere re°�ieV9°ed for all Salriiple locations for OViober, 2011 NV trans V1 1ptlon errors avers
detected. The facility appears to be doing a good job of accurately transcribing data.
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: Todd Crawford
Date: February 1, 2012
Date: February 1, 2012