NC0043320_Lab Certification Inspection_20090810

ATA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
August 10, 2009
5061
Mr. Alex Leonard / H.T. Davidson
Burlington Industries - Richmond Plant
P.O. Box 250
Cordova, NC 28330-
DENR-F
tt J A Q
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC VVW/GW LC)
Maintenance Inspection
Dear Mr. Davidson :
Enclosed is a report for the inspection performed on June 24, 2009 by Ms. Tonja Springer. Where
finding(s) are cited in this report, a response is required. Within thirty days of receipt, please supply this
office with a written item for item description of how these finding(s) were corrected. If the finding(s)
cited in the enclosed report are not corrected, enforcement actions may be recommended. 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
email or if you have questions or need additional information, please contact us at 919-733-3908.
Sincerely,
tad -
Pat Donnelly
Certification Branch Manager
Laboratory Section
Enclosure
cc: Tonja Springer
Fayetteville Regional Office
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: [phone] l FAX: [phone]
Internet: www.dwglab.org
An Equal Opportunity 1 Atfirmative'Action Employer Customer Service: 1-877-623-6748 www.ncwaterquality.org
NorthCarolina
/Vat/traI4i

On -Site Inspection Report
LABORATORY NAME: Burlington Industries — Richmond Plant
NPDES PERMIT #: NC0043320
ADDRESS: P.O. Box 250
Cordova, NC 28330
CERTIFICATE #: #5061
DATE OF INSPECTION: June 24, 2009
TYPE OF INSPECTION: Field Maintenance
AUDITOR(S): Tonja Springer
LOCAL PERSON(S) CONTACTED: Paul Smart, Alex Leonard and H.T. Davidson
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 facility has all the equipment necessary to perform the analyses. The laboratory was clean, well
organized and maintained, and of adequate size to perform the analyses specified on the certificate.
Technical Assistance documents for all certified parameters were provided at the time of the inspection.
Finding A is a new policy that has been implemented by our program since the last inspection.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Dissolved Oxygen (DO) — Standard Methods, 18th Edition, 4500 0 G
Total Residual Chlorine — Standard Methods, 18th Edition, 4500 CI G
A. Finding: The calibration time of the meter and/or daily check standard is not documented.
Requirement: A record of instrument calibration where applicable, must be filed in an orderly
manner so as to be readily available for inspection upon request. Ref: 15A NCAC 2H .0805 (g)
(2), Technical Assistance for Field Analysis of Dissolved Oxygen, and Technical Assistance for
Field Analysis of Total Residual Chlorine.
pH —Standard Methods, 18th Edition, 4500 H+ B
Dissolved Oxygen (DO) — Standard Methods, 18th Edition, 4500 0 G
Temperature — Standard Methods, 18th Edition, 2550 B
B. ' Finding: The temperature sensing device on the D.O. and pH meters has not been calibrated
against an NIST certified or traceable thermometer annually (i.e., every 12 months).
Requirement: All temperature sensing devices on meters must be calibrated against a NIST
certified or NIST traceable thermometer annually (i.e., every 12 months) and proper corrections

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#506i Burlington Industries — Richmond Plant
made and documented. The meter reading must . be less than 1°C from the NIST certified
reading to be acceptable. Document the serial number and manufacturer of the NIST
thermometer that was used in the comparison. Document any correction that applies (even if
zero) on both the meter and on a separate sheet to be filed. Ref: Technical Assistance for Field
Analysis of Dissolved Oxygen, Technical Assistance for Field Analysis of pH, and Technical
Assistance for Field Analysis of Temperature.
Total Residual Chlorine — Standard Methods, 18th Edition, 4500 CI G
Comment: The laboratory has been verifying all 3 gel standards each analysis day on the incorrect meter
program. Per the Technical Assistance for Field Analysis of Total Residual Chlorine, calibration checks
must be for the curve and/or program used for sample analysis. These standards must be verified
initially and every 12 months thereafter, with the standard curve. It is only necessary to verify the gel
or sealed liquid standard which falls within the concentration range of the curve used to measure
sample concentrations. For example, if you are measuring samples against a low range curve, a 200
lag/L standard would be verified, and not the 800 pg/L standard since the 800 standard would be
measured using a high range curve. The assigned values will be used for the next twelve months, or
until a new curve verification is performed. The gel/liquid standard verification must be performed for
each instrument on which they are to be used. If multiple instruments and/or standard sets are used,
each must have assigned values specific for the instrument and standard set. During the inspection the
gel standard was verified on the correct program (86) and assigned a true value. No further response
is necessary for this finding.
C. Finding: The range of the annual curve verification was 10-200 pg/L. While this range brackets the
concentrations of all routine samples analyzed, it does not bracket the concentration of the annual
Proficiency Testing samples (PT).
Requirement: The concentrations of the calibration standards must bracket the concentrations of
the samples analyzed. Ref: Technical Assistance for Field Analysis of Total Residual Chlorine,
Please submit a copy of the new verification curve with the inspection report reply).
Recommendation: It is recommended that the annual curve verification be performed using the
following concentrations: 10, 25, 50, 200, and 400 pg/L.
Conductivity — Standard Methods, 18th Edition, 2510B
Comment: The benchsheet did not have a space to document the collection and analysis time. The
North Carolina Administrative Code, 15A NCAC 2H .0805 (g) (1) and the Technical Assistance for Field
Analysis of Conductivity documentrequire 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 laboratory was sent an example of a benchsheet that included a space to
document the collection and analysis time. The laboratory indicated they will begin using this
benchsheet. No further response is necessary for this finding.
D. Finding: The Automatic Temperature Compensator (ATC) has not been verified.
Requirement: The internal Automatic Temperature Compensator (ATC) must be verified every
12 months and the process documented. Other certified laboratories may provide assistance in
meeting this requirement. 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. This may require the analysis of a third
temperature reading that is > 25°C. Ref: Technical Assistance for Field Analysis of Conductivity
(See Attachment for Procedures). Please send a copy of the verification to our office with
your reply.

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, #5061 Burlington Industries — Richmond Plant
IV. 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 Quality. Data was reviewed
for Burlington Industries — Richmond Plant (NPDES #NC0043320) for March and May, 2009. The
following error was noted:
Date
Parameter
Location
Value on Benchsheet
Value on DMR
3/28/2009 '
Temperature
Effluent
12 °C
11 °C
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 forwarded to the Regional Office.
CONCLUSIONS:
Correcting the above -cited findings and implementing the recommendations will help this lab to produce
quality data and meet certification requirements. The inspector would like to thank the staff for its
assistance during the inspection and data review process. Please respond to all findings.
Report prepared by: Tonja Springer
Report reviewed by: Ramon L. Cook
Date:7/13/2009
Date:7/20/2009

Automatic Temperature Compensator Check — Conductivity (NC WW/GW LC Policy 02/2006)
The internal Automatic Temperature Compensator (ATC) must be verified every 12 months and the
process documented. Other certified laboratories may provide assistance in meeting this requirement.
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. This may require the analysis of a third temperature reading that is > 25°C.
Automatic Temperature Compensator (ATC) Check for the conductivity meter:
1. Pour an adequate amount of conductivity standard into a beaker or other container and analyze
at 25°C. Document the temperature and conductivity value.
2. Lower the temperature of the standard by placing the container in cool water or a refrigerator to
less than the lowest anticipated sample temperature and analyze. Documentthe temperature
and conductivity value.
3. If samples greater than 25°C are to be analyzed, perform the following additional step: Place the
container in warm water or a water bath and raise the temperature above 25°C to greater than
the highest anticipated sample temperature and analyze. Document the temperature and
conductivity value.
As the temperature increases or decreases, the value of the conductivity standard must be within ±
10% of the true value of the standard.
Anticipated temperatures can be obtained from a review of the Discharge Monitoring Reports (DMRs)
from the peak summer and winter months. Historical data should provide a reasonably accurate
estimation of ranges that will bracket the expected sample temperatures.