#5122_2018_0502_MC_FINAL

To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5122
Laboratory Name:
Alcoa, Inc. Badin
Inspection Type:
Field Industrial Maintenance
Inspector Name(s):
Beth Swanson, Michael Cumbus
Inspection Date:
May 2, 2018
Date Forwarded for Initial
May 15, 2018
Review:
Initial Review by:
Tonja Springer
Date Initial Review
May 15, 2018
Completed:
❑ Insp. Initial
® Insp. Reg
Cover Letter to use:
❑Insp. No Finding
❑Corrected
❑Insp. CP
❑Insp. Reg. Delay
Unit Supervisor/Chemist III:
Beth Swanson
Date Received:
May 16, 2018
Date Forwarded to Admin.:
May 17, 2018
Date Mailed:
May 17, 2018
Special Mailing Instructions:
Email to: Wes Bell wes.bell(doncdenr.gov;
Roberto Scheller
Roberto.schellerQncdenr.gov,

May 17, 2018
5122
Mr. Randall Kiser
Alcoa Inc. Badin
P.O. Box 576
Badin, NC 28009
ROY COOPER
MICHAEL S. REGAN
,PO ;U
LINDA CULPEPPER
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Kiser:
Enclosed is a report for the inspection performed on May 2, 2018 by Beth Swanson and Michael
Cumbus. 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. Please describe the steps taken to prevent recurrence and include an implementation
date for each corrective action. 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.
A copy of the laboratory's Certified Parameter List at the time of the audit is attached. This list will
reflect any changes made during the audit. 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 me at [phone] ext. 259.
Sincerely,
qlk�
Beth Swanson
Technical Assistance & Compliance Specialist
Division of Water Resources
Attachment
cc: Dana Satterwhite, Michael Cumbus

LABORATORY NAME:
NPDES PERMIT :
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
I. INTRODUCTION:
Alcoa, Inc. Badin
NC0004308
293 Hwy 740
Badin, NC 28009
5122
May 2, 2018
Field Industrial Maintenance
Beth Swanson and Michael Cumbus
Randall Kiser
This laboratory, was inspected by representatives of the North Carolina Wastewater/Groundwater
Laboratory Certification (NC WW/GW LC) program to verify its compliance with the requirements
of 15A NCAC2H .0800 for the analysis of environmental samples.
II. GENERAL COMMENTS:
Records are well organized and easy to retrieve. Staff were forthcoming and seemed eager to
adopt necessary changes.
All required Proficiency Testing (PT) Samples for the 2018 PT Calendar Year have not yet been
analyzed. The laboratory is reminded that results must be received by this office directly from the
vendor by September 30, 2018.
Requirements that reference 15A NCAC 2H .0805 (g) (1), stating "Data pertinent to each analysis
must be maintained for five years. Certified Data must consist of date collected, time collected,
sample site, sample collector, and sample analysis time. The field benchsheets must provide a
space for the signature or initials of the analyst and proper units of measure for all analyses", are
intended to be a requirement to document all pertinent information for historical reconstruction of
data. It is not intended to imply that existing records are not adequately maintained unless the
Finding speaks directly to that
Contracted analyses are performed by TestAmerica Savannah (Certification #269).
Quality Assurance Policies for Field Laboratories and Approved Procedure documents for the
analysis of the facility's currently certified Field Parameters were provided at the time of the
inspection.

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#5122 Alcoa, Inc. Badin
Documentation
Comment: The laboratory benchsheets were lacking the following pertinent data: facility name,
permit number, instrument identification, method reference and sample analysis time. The NC
WW/GW LC Approved Procedure for the Analysis of Temperature and NC WW/GW LC
Approved Procedure for the Analysis of pH documents state: The following must be documented
in indelible ink whenever sample analysis is performed: Time of sample analysis, facility name,
permit number, thermometer/instrument identification (serial number preferred) and method
reference. Acceptable corrective action (i.e., the facility name, permit number, method reference,
instrument identification and a note that samples were analyzed in situ, were added to the cover of
the bound notebook where data is recorded) was performed by the laboratory and approved by
the auditor during the inspection. No further response is necessary for this Finding.
Recommendation: It is recommended that the laboratory create and maintain an Equipment
Maintenance Log to document routine service to the instruments.
A. Finding: Error corrections are not properly performed.
Requirement: 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 change
documented. Ref: Quality Assurance Polices for Field Laboratories.
B. Finding: The laboratory needs to increase the traceability documentation of purchased
materials and reagents.
Requirement: 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. 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. Ref: Quality Assurance Policies for Field Laboratories.
Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A
NCAC 2H .0805 (g) (1).
Comment: Utilizing the reagent log supplied during the inspection to record pH buffer
information will satisfy this requirement.
C. Finding: Annual verification documentation of the temperature sensing probe on the pH
meter used for Temperature measurements does not include the serial number or unique
identifier of the device being checked.
Requirement: All compliance temperature -measuring devices without a valid NIST
certificate must be checked initially and every 12 months against an NIST traceable
temperature -measuring device and the process documented. Documentation must include

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#5122 Alcoa, Inc. Badin
the serial number of the device being checked. Ref: NC WW/GW LC Approved Procedure
for the Analysis of Temperature.
Proficiency Testing
D. Finding: Additional Quality Control (QC) beyond what is routine for Compliance Samples
is being analyzed with PT Samples.
Requirement: Laboratories shall conduct the analyses in accordance with their routine
testing, calibration and reporting procedures, unless otherwise specified in the instructions
supplied by the Accredited PT Sample Provider. This means that they are to be logged in
and analyzed using the same staff, sample tracking systems, standard operating
procedures including the same equipment, reagents, calibration techniques, analytical
methods, preparatory techniques (e.g., digestions, distillations and extractions) and the
same quality control acceptance criteria. PT Samples shall not be analyzed with additional
quality control. They are not to be replicated beyond what is routine for Compliance
Sample analysis. Although, it may be routine to spike Compliance Samples, it is neither
required, nor recommended, for PT Samples. PT Sample results from multiple analyses
(when this is the routine procedure) must be calculated in the same manner as routine
Compliance Samples. Ref: Proficiency Testing Requirements, May 31, 2017, Revision 2.0.
Temperature — Standard Methods, 2550 B-2010 (Aqueous)
Recommendation: It is recommended that the laboratory report temperature in whole numbers.
The laboratory is currently reporting temperature to the nearest 0.1 °C.
E. Finding: The temperature sensor on the Accumet AP61 pH meter used to obtain reported
temperature values was not checked against a National Institute of Standards and
Technology (NISI) traceable thermometer initially.
Requirement: All compliance temperature -measuring devices without a valid NIST
certificate must be checked initially and every 12 months against an NIST traceable
temperature -measuring device and the process documented. Documentation must include
the serial number of the device being checked. The serial number, stated accuracy and
expiration date of the NIST traceable temperature -measuring device used in the
comparison must also be documented. Verification data must be kept on file and be
available for inspection for 5 years. Ref: NC WW/GW LC Approved Procedure for the
Analysis of Temperature.
Comment: The current probe was put into use in May 2017 and the laboratory performed
verification checks on June 13, 2017 and April 26, 2018.
pH — Standard Methods, 4500 H+B-2011 (Aqueous)
F. Finding: The laboratory is not analyzing a post -analysis check standard buffer when
analyses are performed at multiple sample sites.
Requirement: When performing analyses at multiple sample sites, a post -analysis
calibration verification using the check standard buffer must be analyzed at the end of the
run. It is recommended that a mid -day check standard buffer be analyzed when samples
are analyzed over an extended period of time. The post -analysis check standard buffer(s)
must read within ±0.1 S.U. or corrective actions must be taken. If recalibration is
necessary, all samples analyzed since the last acceptable calibration verification must be

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#5122 Alcoa, Inc. Badin
reanalyzed, if possible. If samples cannot be reanalyzed, the data must be qualified. Ref:
NC WW/GW LC Approved Procedure for the Analysis of pH.
Comment: When analyzing a post -analysis check or a mid -day check, the time must be
documented along with the result.
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North
Carolina Division of Water Resources. Data were reviewed for Alcoa, Inc. Badin (NPDES
#NC0004308) for May 2017, October 2017 and December 2017. No transcription errors were
observed. The facility appears to be doing a good job of accurately transcribing data.
V. CONCLUSIONS:
Correcting the above -cited Findings and implementing the Recommendations will help this
laboratory to produce quality data and meet Certification requirements. The inspector would like
to thank the staff for their assistance during the inspection and data review process. Please
respond to all Findings and include supporting documentation, implementation dates
and steps taken to prevent recurrence for each corrective action.
Report prepared by: Michael Cumbus Date: May 7, 2018
Report reviewed by: Tonja Springer Date: May 15, 2018

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