#5654_2016_0621_JS_FINAL

To be attached to all inspection reports in-house only.
Laboratory Cert. #:
Laboratory Name:
Inspection Type:
Inspector Name(s):
Inspection Date:
Date Report Completed:
Date Forwarded to Reviewer:
Reviewed by:
Date Review Completed:
Cover Letter to use:
Unit Supervisor/Chemist III:
Date Received:
Date Forwarded to Admin:
Date Mailed:
Special Mailing Instructions:
5654
SGL Carbon, LLC
Field Industrial Initial
Jason Smith
June 21, 2016
July 18, 2016
July 18, 2016
Jason Smith
Tonia Springer
❑ Insp. Initial
❑ Insp. Reg.
❑ Insp. No Finding
❑ Insp. CP
® Corrected
❑ Insp. Reg. Delay
Todd Crawford
July 19, 2016
July 21, 2016
July 22, 2016

Water Resources
ENVIRONMENTAL QUALIFY
July 22, 2016
5654
Mr. Jeff Woodruff
SGL Carbon, LLC
307 Jamestown Rd.
Morganton, NC 28655-
PAT MCCRORY
DONALD R. VAN DER VAART
S. JAY ZIMMERMAN
iu�es is �.
SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Woodruff:
Enclosed is a report for the inspection performed on June 21, 2016 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 (919) 733-
3908 ext. 251.
Sincerely,
Todd Crawford
Technical Assistance & Compliance Specialist
NC WW/GW Laboratory Certification Branch
Attachment
cc: Dana Satterwhite, Jason Smith

LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
On - Site Inspection Report
SGL Carbon, LLC
NC0005258
307 Jamestown Road
Morganton, NC 28655
5654
June 21, 2016
Field Industrial Initial
Jason Smith
LOCAL PERSON(S) CONTACTED: Jeff Woodruff
INTRODUCTION:
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:
Although this is considered an initial inspection for Field certification, the laboratory was previously
certified as a Non -Field laboratory (#609). The change in certification status was made effective
June 2, 2014.
The facility has all the equipment necessary to perform the analyses. The system for traceability of
standards and reagents is thorough, well maintained and easy to follow.
All required Proficiency Testing (PT) samples for the 2016 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, 2016.
Contracted analyses are performed by Blue Ridge Labs (Certification #275).
Current Quality Assurance Policies for Field Laboratories and Approved Procedure documents
for the analysis of the facility's currently certified methods were provided at the time of the
inspection.
Additionally, the Approved Procedure for the Analysis of Total Residual Chlorine (TRC) was
provided and discussed because the laboratory is expecting TRC to be required to be analyzed
when the NPDES permit is renewed. The laboratory is performing preliminary monitoring at this
time; however, the meter being used is not approved for low level TRC analysis for reporting.
The laboratory is encouraged to seek guidance from our office when purchasing an approved
meter and prior to beginning TRC analysis.

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#5654 SGL Carbon, LLC
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
Comment: Error corrections were not performed properly. Some instances of overwriting were
observed and the date of the error correction was not documented. The NC WW/GW LC 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 change
documented. All data and log entries must be written in indelible ink. Pencil entries are not
acceptable. Notification of acceptable corrective action (i.e., a statement that beginning 6/21/2016,
error corrections are performed properly using a single line to mark through the error and initialing
and dating the error) was received by email on 6/22/2016. No further response is necessary for
this Finding.
Proficiency Testing
Comment: The laboratory was not analyzing Proficiency Testing (PT) samples in the same
manner as compliance samples. The laboratory's common practice was to analyze a known
standard along with the PT sample as additional quality control. The NC WW/GW LC Proficiency
Testing Requirements document, February 20, 2012, Revision 1.2 states: All PT samples are to be
analyzed and the results reported in a manner consistent with the routine analysis and reporting
requirements of compliance samples and any other samples analyzed according' to the
requirements of 15A NCAC 2H .0800. Notification of acceptable corrective action (i.e., a statement
that beginning with the 2016 PT samples, known standards will not be analyzed with PT samples)
was received by email 6/22/2016. No further response is necessary for this Finding.
pH — Standard Methods, 4500 H+ B-2000
Comment: The laboratory was analyzing duplicate samples for pH. This could lead to difficulty
meeting the requirement of reporting all effluent data; however, all pH data was reviewed for 2015
and 2016 and all results were reported because all duplicate results were identical to the sample
results during this time period. Duplicate analyses are not required for Field parameters and the
laboratory stated that they implemented the recommendation to no longer analyze duplicate
samples in an email received on 6/22/2016.
Temperature — Standard Methods, 2550 B-2000
Comment: The analysis times were not being properly documented. One time was documented
for effluent, upstream and downstream analyses. The North Carolina Administrative Code, 15A
NCAC 2H .0805 (g) (1) states: Certified Data must consist of date collected, time collected, sample
site, sample collector, and sample analysis time. Notification of acceptable corrective action (i.e.,
an updated benchsheet with individual analysis times for each sample put into use on 6/22/2016)
was received by email on 6/22/2016. No further response is necessary for this Finding.
Comment: The NIST traceable thermometer was last recalibrated in 2009. The NC WW/GW LC
Approved Procedure for Analysis of Temperature document states: NIST traceable temperature
measuring devices used only to verify the calibration of other thermometers or temperature
sensors (i.e., limited use only) must be recalibrated in accordance with the manufacturer's
recalibration date and the process documented. If no recalibration date is given, the NIST
traceable temperature measuring device must be recalibrated every 5 years. Notification of
acceptable corrective action (i.e., the NIST thermometer was recalibrated on 6/28/16, all

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#5654 SGL Carbon, LLC
thermometers in use were verified on 6/29/16 and a statement that the NIST thermometer will
be recalibrated every five years in the future) was received by email on 6/29/16 and 7/15/16. No
further response is necessary for this Finding.
Comment: The thermometer used for upstream Temperature measurements was 0.6 °C below
the NIST traceable value when verification was last performed. This verification was performed
prior to the following new requirement and was acceptable at the time it was performed. The NC
WW/GW LC Approved Procedure for Analysis of Temperature document states: All
thermometers and temperature measuring devices used for compliance monitoring must be
checked every 12 months against a NIST traceable temperature measuring device and the
process documented. The thermometer/ meter readings must be less than or equal to 0.5 °C
from the NIST traceable temperature measuring device reading. If it is, no correction factor
would be applied. If it is not, the thermometer/meter may not be used for compliance monitoring.
Notification of acceptable corrective action (i.e., verification was performed on 6/29/2016 after
NIST traceable thermometer calibration and the temperature correction was -0.4 °C) was
received by email on 6129/2016. No further response is necessary for this Finding.
Recommendation: It is recommended that all temperatures reported for compliance
monitoring, be reported in whole numbers as recommended by the Precision in Discharge
Monitoring Reports document.
pH — Standard Methods, 4500 H+ B-2000
Temperature —Standard Methods, 2550 B-2000
Comment: Identification of instruments was not documented on the benchsheet. The NC WW/GW
LC Approved Procedure for the Analysis of pH and Approved Procedure for the Analysis of
Temperature documents state: The following must be documented in indelible ink whenever
sample analysis is performed: Instrument/Thermometer Identification. Notification of acceptable
corrective action (i.e., updated benchsheets with instrument and thermometer identification
documented which were put into use on 6/22/2016) was received by email on 6/22/2016. No
further response is necessary for this Finding.
Comment: The name of the facility was not documented on the benchsheets. The NC WW/GW
LC Approved Procedure for the Analysis of pH and Approved Procedure for the Analysis of
Temperature state: The following must be documented in indelible ink whenever sample analysis is
performed: Sampling site including facility name and location, ID, etc. Notification of acceptable
corrective action (i.e., updated benchsheets documenting the facility name and location which were
put into use on 6/22/2016) was received by email on 6/22/2016. No further response is
necessary for this Finding.
IV. PAPER TRAIL INVESTIGATION:
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 SGL Carbon, LLC (NPDES
permit # NC0005258) for June, September and November 2015. No transcription errors were
detected. The facility appears to be doing a good job of accurately transcribing data.
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.

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#5654 SGL Carbon, LLC
Report prepared by: Jason Smith Date: July 18, 2016
Report reviewed by: Tonja Springer Date: July 19, 2016