#183_0312_final

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NCDEN
North Carolina Department of Environment and Natural Resources
Pat McCrory Donald R. van der Vaart
Governor Secretary
April 2, 2015
183
Kapstone Kraft Paper Corporation
Neal Davis
100 Gaston Road
Roanoke Rapids, NC 27870-1900
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Davis:
Enclosed is a report for the inspection performed on March 12, 2015 by Todd Crawford. 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 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.
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.
Attachment
cc: Todd Crawford
Sincerely,
Dana Satterwhite, Environmental Program Supervisor
Division of Water Resources
Water Sciences 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
Phone: [phone] l FAX: [phone]
Internet: www.dwalab.oro
An Equal Opportunity 1Affiirmative Action Employer

INSPECTION REPORT ROUTING SHEET
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 Linda:
Date Mailed:
183
Kapstone Kraft Paper Corporation Roanoke Rapids Mill
Industrial Maintenance
Todd Crawford
March 12, 2015
March 26, 2015
March 26, 2015
Tonia Springer
March 26, 2015
❑ Insp. Initial ® Insp. Reg.
❑ Insp. No Finding ❑ Insp. CP
❑ Corrected ❑ Insp. Reg. Delay
Dana Satterwhite
3/26/2015
4/2/2015
4/2/2015

On -Site Inspection Report
LABORATORY NAME: Kapstone Kraft Paper Corporation, Roanoke Rapids Mill
NPDES PERMIT # : NC0000752
ADDRESS: 100 Gaston Road
Roanoke Rapids, NC 27870-1900
CERTIFICATE #: 183
DATE OF INSPECTION: March 12, 2015
TYPE OF INSPECTION: Industrial Maintenance
AUDITOR(S): Todd Crawford
LOCAL PERSON(S) CONTACTED: Neal Davis, Paul Kinnon and Michael Knudson
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.
GENERAL COMMENTS:
The facility has all the equipment necessary to perform the analyses. The system for traceability of
standard and reagent preparation is effective, thorough and easy to follow. Laboratory personnel
communicate well with sample collectors and coordinate sample analyses effectively to manage workload
and holding times.
Proficiency Testing (PT) samples for the 2015 proficiency testing calendar year have not yet been
analyzed. The laboratory is reminded that these results must be submitted to this office directly from the
vendor by September 30, 2015.
Contracted analyses are performed by Meritech, Inc. (Certification #165).
The requirements associated with Findings A and B have been implemented by our program since the
last inspection.
FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Standard Operating Procedures
Recommendation: It is recommended that Standard Operating Procedures (SOPs) contain a sheet
where review dates can be documented. This gives the lab credit for reviewing the SOPs even when
revisions may not be needed.
Recommendation: It is recommended that SOPs include a revision and review history with relevant
dates (e.g., effective, review and revision dates) and a brief description of the change(s) made.

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# 183 Kapstone Kraft Paper Corporation, Roanoke Rapids Mill
A. Finding: The laboratory does not have a documented plan for proficiency testing (PT)
procedures.
Requirement: 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. Ref: 15A
NCAC 2H .0805 (a) (7).
Requirement: Laboratories must have a documented plan (this is usually detailed in the
laboratory's Quality Assurance Manual) of how they intend to cover the applicable program
requirements for proficiency testing per their scope of accreditation. This plan shall cover any
commercially available proficiency testing and any inter -laboratory organized studies, as
applicable. The laboratory must also be able to explain when proficiency testing is not possible for
certain parameters and provide a description of what the laboratory is doing in lieu of proficiency
testing. This shall be detailed in the plan. The plan must also address the laboratory's process for
submission of proficiency testing results and related corrective action responses. Laboratory
Standard Operating Procedures (SOPs) must address how low level samples will be analyzed,
including concentration of the sample or adjustment of the normality of a titrant. These instructions
shall be followed when the concentration of a PT sample falls below the range of their routine
analytical method. Instructions shall also be included in the laboratory's SOP for how high level
samples will be analyzed, including preparation of multiple dilutions of the sample. These
instructions will be followed when the concentration of a PT falls above the range of their routine
analytical method. Ref: Proficiency Testing Requirements, February 20, 2012, Revision 1.2.
PH — Standard Methods, 4500 H+B-2000
Comment: The true value of the calibration check buffer was not stated on the calibration worksheet. The
NC WW/GW LC Approved Procedure for the Analysis of pH document states: The following must be
documented in indelible ink whenever sample analysis is performed: True value for the check standard
buffer. Demonstration of acceptable corrective action (i.e., an updated QA logsheet showing the true
value of the pH check buffer and a stated implementation date of 4/1/15) was received by email on
3/18/15. No further response is necessary for this finding.
Conductivity —Standard Methods, 2510 B-1997
Comment: The time of analysis was not documented on the benchsheet. The NC WW/GW LC Approved
Procedure for the Analysis of Specific Conductance (Conductivity) document states: The following must
be documented in indelible ink whenever sample analysis is performed: Date and time of sample analysis
to verify the 28 day holding time is met. Alternatively, one time may be documented for collection and
analysis with the notation that samples are measured in situ or immediately at the sample site.
Demonstration of acceptable corrective action (i.e., newly designed Field parameter worksheet with space
to document the analysis time and a stated implementation date of 4/1/15) was received by email on
3/18/15. No further response is necessary for this finding.
Comment: The Automatic Temperature Compensator (ATC) had not been verified. The North Carolina
Wastewater/Groundwater Laboratory Certification Approved Procedure for the Analysis of Specific
Conductance (Conductivity) document states: The ATC must be verified annually (i.e., every twelve
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. This may require the analysis of a third temperature
reading that is > 25 °C. Demonstration of acceptable corrective action (i.e., documentation of an
acceptable ATC check) was received by email on 3/18/15. No further response is necessary for this
finding.

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# 183 Kapstone Kraft Paper Corporation, Roanoke Rapids Mill
PH — Standard Methods, 4500 H+B-2000
Conductivity —Standard Methods, 2510 B-1997
Temperature — Standard Methods, 2550 B-2000
Dissolved Oxygen — Standard Methods, 4500 O G-2001
Comment: The units of measure were not documented in the Field parameters logbook. The North
Carolina administrative Code, 15A NCAC 2H .0805 (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 item must be recorded each time samples are analyzed.
Demonstration of acceptable corrective action (i.e., newly designed Field parameter worksheet showing
proper units and a stated implementation date of 4/1/15) was received by email on 3/18/15. No further
response is necessary for this finding.
Comment: The facility name was not documented in the Field parameters logbook. The NC WW/GW LC
Approved Procedure for the Analysis of pH, NC WW/GW LC Approved Procedure for the Analysis of
Specific Conductance (Conductivity), NC WW/GW LC Approved Procedure for the Analysis of
Temperature and NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen documents
state: The following must be documented in indelible ink whenever sample analysis is performed: Sample
site including facility name and location, ID, etc. This requirement is a new policy that has been
implemented by our program since the last inspection. Demonstration of acceptable corrective action (i.e.,
a newly designed Field parameter worksheet showing the facility name and a stated implementation date
of 4/1/15) was received by email on 3/18/15. No further response is necessary for this finding.
Comment: The Field parameter meters were not identified in the Field parameters logbook. The NC
WW/GW LC Approved Procedure for the Analysis of pH, NC WW/GW LC Approved Procedure for the
Analysis of Specific Conductance (Conductivity), NC WW/GW LC Approved Procedure for the Analysis of
Temperature and NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen documents
state: The following must be documented in indelible ink whenever sample analysis is performed:
Instrument identification. This requirement is a new policy that has been implemented by our program
since the last inspection. Demonstration of acceptable corrective action (i.e., a newly designed Field
parameter worksheet that identifies each field meter and a stated implementation date of 4/1/15) was
received by email on 3/18/15. 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 November and December, 2014 and January, 2015. No
transcription errors were detected. The facility appears to be doing a good job of accurately transcribing
data.
V. CONCLUSIONS:
Correcting the above -cited finding 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 and include
an implementation date and supporting documentation for each corrective action.
Report prepared by: Todd Crawford Date: March 26, 2015
Report reviewed by: Tonja Springer Date: March 26, 2015