NC0005321_Compliance Evaluation Inspection_19950601

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State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., PE., Director
June 1, 1995
Mr. Ronald Radford
Alpha Cellulose Corporation
P.O. Box 1305
Lumberton, NC 28358
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FAYETTEVIla REG. OFFICEj
SUBJECT: Initial Laboratory Certification Inspection
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Dear Mr. Radford:
Enclosed is a copy of the subject inspection report as
prepared by Ms. Cooper. Each of the deviations must be corrected
prior to certification. Within sixty days, please supply this
office with a written item for item description of how these
deviations were corrected. As a certification requirement, your
laboratory must continue to carry out the requirements set forth in
NCAC 15R 2H .0800.
Thank you for your cooperation during the inspection. Please
contact us at 919-733-3908 if you have questions or need additional
information.
Sincerely,
William B. Edwards', Jr.
Laboratory Section
Enclosure
cc: Norman L. Good
Harvi Cooper
Fayetteville Regional Office
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Laboratory Section
4405 Reedy Creek Road, Raleigh, North Carolina 27607-6445 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

ON -SITE INSPECTION REPORT
LABORATORY NAME & ADDRESS:
Alpha Cellulose Corporation
P.O. Box 1305
Lumberton, NC 28358
CERTIFICATE NO.:
DATE OF INSPECTION: May 24, 1995
TYPE OF INSPECTION: Initial
EVALUATORS: Harvi C. Cooper
LOCAL PERSON CONTACTED: Chuck Oxendine and Ronald Radford
I. INTRODUCTION:
This laboratory
requirements of
samples.
was inspected to verify its compliance with the
15A NCAC 2H .0800 for the analysis of environmental
II. GENERAL COMMENTS:
Lab is spacious and well equipped. Instruments and facilities are well
maintained. Records are well kept and data looked good. A few minor
deviations were found and some further quality control procedures need
to be implemented.
III.DEVIATIONS, REQUIREMENTS AND COMMENTS:
BOD
Deviation: Lab is not currently checking BOD effluent samples for
residual chlorine and dechlorinating when necessary.
Requirement: Lab must check all BOD samples for residual chlorine and
dechlorinate as required in Standard Methods 18th Edition and document
the process.
Residual Chlorine
Deviation: The lower reporting limit for Residual Chlorine is below
the lowest calibration standard analyzed. Lab is currently calibrating
with a 1.0 and a 10.0 mg/L standard.

Page 2 Alpha Cellulose
Residual Chlorine contd.
Requirement: For analytical procedures requiring analysis of a series
of standards, the concentration of these standards must bracket the
concentration of the samples analyzed. One of the standards must have
a concentration equal to the laboratory's lowerlreporting
concentration for the parameter involved.
Comment: Lab has established 0.01 ug/L as the lower reporting
concentration for Residual Chlorine. Lab is currently using anion
selective electrode due to color interferences in the effluent.
Documentation of the lab's ability to meet this established lower
reportingconcentration must be submitted to this office for review.
Deviation: The daily 1.0 mg/L check standard for Residual Chlorine is
often outside the + 10% acceptance criteria.
Requirement: A daily mid -range check standard must meet a + 10%
acceptance criteria.
Specific Conductance
Deviation: Lab has not documented the required calibration standards
for Specific Conductance analyses.
Requirement: Each day of use, the Conductivity meter must be
calibrated with a high standard, the cell constant must be calculated
and the process documented. A low and mid -range standard must also be
analyzed and the results documented.
Comment: Lab has developed a new bench sheet for the calibration
records for pH, Conductivity and TDS, but has not documented all of
the required standards for Conductivity. Considering the range of
concentrations of samples analyzed, it is recommended to use a 10,000
umhos/cm standard in order to bracket sample concentrations as
required.
Ammonia
Deviation: Ammonia samples are not checked for
dechlorinated at the time of sampling.
chlrine and
Requirement: Lab must check samples to be analyzed.for Ammonia for
chlorine, treat with an approved dechlorinating agent where necessary
at the time of sampling and document the process.
Comment: Lab is collecting a composite sample to be used for several
analyses. Recommend splitting a sample for Ammonia analyses and
dechlorinating immediately following the 24 hr. composite period.

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Page(3
Alpha Cellulose
Deviation: Lab is not
each group of Ammonia
Requirement: Lab must
each group of Ammonia
documenting the analysis of a reagent blank with
samples.
document the analysis of a reagent blank with
samples.
Deviation: Lab is omitting the distillation procedure for Ammonia
analysis but has not conducted the distillationl comparison study
required to document that the distillation step; is unnecessary for a
particular waste stream. •
Requirement: Lab must submit a copy of the distillation comparison
study to this office for review. This is required if the distillation
step is not conducted as part of the ammonia analyses.
Comment: Lab may contract with a commercial lab to conduct the
distillation part of the comparison study on each waste stream that
the distillation step will be excluded from in Ammonia analysis.
Enclosed is a memo on the distillation comparison requirement.
Total Suspended Residue
Deviation: Lab is not analyzing a quarterly check s
Suspended Residue.
tandard for Total
Requirement: Lab must analyze -and indicate the true' value and percent
recovery of a Total Suspended Residue check standard quarterly.
General
Deviation: Lab is using pencil to record data on bench sheets.
Requirement: Lab must use ink for all documentationL. If corrections
are made, a slash must be drawn through the error and the analyst must
initialthe correction.
Deviation: Lab has not documented refrigerator temperatures on the
refrigerator log.
Requirement: Lab must record temperatures and initial the temperature
log each day of use, for all refrigerators, incubators and ovens.ref:
15A NCAC 2H .0805 (7)(J) pcq.7
Deviation: All lab thermometers are not calibrated against a NIST
certified thermometer annually. Degree deviations are not listed
tag on the thermometers.
on a
Requirement: All thermometers must meet NIST specifications for
accuracy or must be calibrated against a NIST certified thermometer
annually and proper corrections made. Ref: 15A NCAC 2H .0805 (7)(0)
pg. 7

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Alpha Cellulose
Comment:. Lab has calibrated some of the thermometers but has done so
at approximately 20°C for all thermometers calibrated. A temperature
within the range that the individual thermometers are required to
operate should be selected for calibration.
IV. DATA REVIEW:
Data review consisted of a.review of the bench sheets and DMR's for
the -months of September 1994 thru March 1995. No problems in adhering
to required hold times or in properly calculating data were detected.
. CONCLUSION:
This lab is doing a good job overall. Personnel contacted were
cooperative and competent. Documentation of the correction of the
'above deviations mustbe submitted to this office for review.
Correction of the above deviations should help this lab continue to
produce quality data.
Report Prepared by: Harvi C. Cooper Date: May 28, 1995