NC0005321_Lab Certification Maintenance Inspection_19990222

NORTH CAROLINA DEPARTMENT. OF
ENVIRONMENT AND ,NATURAL RESfJURCES
DIVISION OF WATER QUALITY
February 22, 1999
525
Mr. Eric Bolin
Buckeye Lumberton Inc.
P. O. Box 1305
1000 East Noir Street
Lumberton, NC 28359-
1�
FEB 2 5.1999
FAYETTEV LLB
f AEG, OFFiCE
SUBJECT: Laboratory Certification Maintenance Inspection
Dear Mr. Bolin:
Enclosed is a report for the inspection performed on December 9,
1998 by Ms. Harvi C. Cooper. Within thirty days, please supply this office
with a written item for item description of how these violations were
corrected. A response is not required comments o'r recommendations
unless specifically requested. If the violations cited in the enclosed report
are not corrected, enforcement actions will be recommended. For
certification maintenance, your laboratory must continue to carry out the
requirements set forth in 15A NCAC for 2H .0800.
Copies of the checklists completed during the inspection may be
requested from this office. Thank you for your cooperation during the
inspection. Please contact us at 919-733-3908, if you have questions or
need additional information.
Sincerely,
W
Meyer
JamesW.
Laboratory Section
Enclosure
cc: Norman L. Good
Harvi C. Cooper
Fayetteville Regional Office
4405 REEDY CREEK ROAD, RA ICLEIGH, NORTH CLABORATORY SECTION
AROLINA 27607 6445
AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER - 5O%NRECYC ED//I 0% POST CONSUMER PAPER

ON -SITE INSPECTION REPORT
LABORATORY NAME & ADDRESS: Buckeye Lumberton Inc.
1000 East Noir Street
Lumberton, NC 28359-
CERTIFICATE NO.: 525
DATE OF INSPECTION: December 9, 1998
TYPE OF INSPECTION: Maintenance
EVALUATORS: Harvi C. Cooper
LOCAL PERSON CONTACTED: Eric Bolin and Ronald Radford
I. INTRODUCTION:
J
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 laboratory was clean and well organized. Instruments and facilities are well maintained. Several
violations were found and some further quality control procedures have been recommended.
III. VIOLATIONS, REQUIREMENTS, RECOMMENDATIONS AND COMMENTS:
BOD
1) Violation: Analyst indicated that corrective actions were taken when method established control
limits were exceeded, but the corrective actions were not always documented.
Comment: BOD bench worksheets document control limits for the;GGA check standard with space
provided to document various corrective actions when control limits are exceeded.
Requirement: It is the desire of the State of North Carolina that all data generated for any permitted
location under NPDES requirements is to be reported. "Every person subject to [15A NCAC 2B
.0506] shall file certified monitoring reports setting forth the results of tests and measurements
conducted pursuant to NPDES permit monitoring requirements." Ref: 15A NCAC 2B .0506 (a) (1).
Additionally, "the results of all tests of the characteristics of the effluent, including but not limited to
NPDES Permit Monitoring Requirements, shall be reported on monthly report forms." Ref: 15A NCAC
2B .0506 (b) (3) (J).

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The NPDES Permit itself states in Part II, Section D, Monitoring and Records, Number 7 = Recording
Results, "for each measurement or sample taken pursuant to the requirements of this permit, the
permittee shall record the following information...the results of such analyses."
This means all data are reported and none are rejected. If all quality control requirements are not
met, it is required that the data be qualified and the qualification a
back of the
Monitoring Report (DMR). Any rejection of data from the storets wppbe i suedar on eby the agencyylschawhich e
receives the data.
The Quality Control requirements of the method are outlined below:
1. The DO depletion of the dilution water blank must not be more than 0.2 mg/I.
2. The seed controls must deplete at least 2.0 mg/I DO and have at east 11.0 mg/I DO remaining.
3. The samples must also deplete at least 2.0 mg/I DO and have at least 1.0 mg/I DO remaining.
4. No evidence of toxicity should be present. This can only be evident when at least three dilution's
are analyzed. This is characterized by an increasing BOD value as the sample concentration
decreases.
5. The glucose glutamic acid standard must be in the acceptable range of 198 mg/I + 30.5 mg/I.
6. The seed correction, calculated from the seed controls, must be between 0.6 and 1.0 mg/I.
Anytime any of the above quality control requirements are not met, the data must be qualified. The
qualifying statement should indicate that all QC requirements were not met. But the data must always
be reported.
Recommendation: Recommend the qualifying statement be specific
exceeded.
as to the control limit that was
2) Violation: The initial calibration of the DO meter, periodic calibration checks and a calibration
check at the end of the sample set is not documented.
Requirement: When using the membrane electrode, the calibration must be checked at one or two
points frequently to confirm original calibration. ref:. Standard Method, 18 ,Edition - Method 4500-0
G. pg. 4-104.
• Recommendation: Recommend analyst check and document the caflibratl on of the DO meter during,
(every ten samples), and at the end of the sample set. 1
I
3) Violation: 'White -Out" correction fluid was used on BOD benchsheets
Comment: White -Out appeared on benchsheets for the following sletup'dates: 10/29/98, 10/30/98,
11/1/98, 11/9/98, and 11/25/98 .
Requirement: In the event of an error, draw a single line through the error, write the correct result near
the error or in the margin, and initial the correction. "White -Out" or similar products are not to be used.
Reference: SW 846 July 1992 Chapter One, Section .4.6, Laboratory Records.

Page - 3 - Buckeye Lumberton, Inc.
CommMit: The standard operating procedure for BOD needs to be
calibrating the new meter and probe.
Total Suspended Solids
updated to include directions for
Comment: Lab is currently filtering from 50 to 100 mis of sample for effluent monitoring.
Recommendation: Recommend filtering larger volumes of sample to ensure that at least 1.0 mg
residue is retained on the filter. The recommendations for selection of filter and sample sizes from
Standard Methods 18th Edition are as follows: Choose sample volume to yield between 10 and 200
mg dried residue. If more than 10 minutes are required to complete fltration, increase filter size or
decrease sample volume. When very low total suspended solids are encountered (less than 10
mg/L), less dried residue may be collected; compensate by using a high -sensitivity balance (0.002
mg). ref: Standard Methods 18th Edition Method 2540 D. (3)(b) pq. 2-56
Recommendation: Recommend analyzing a blank with each set of Tota',l Suspended Solids
samples.
Settleable Solids
4) Violation: Lab does not have printed bench worksheets for Settleable Residue.
Requirement: All laboratories must use printed laboratory bench worksheets that include a space
to
enter the signature or initials of the analyst, date of analysis, 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. The date and time bah and coliform samples
are removed form the incubator must be included on the laboratory worksheet. ref: 15A NCAC 2H
.0805 (a)(7)(H) pg. 6
General
5) Violation: Lab is not documenting all required sample collection information for effluent composite
and grab samples.
Comment: The pH and Total Residual Chlorine grab sample collection tme is not documented for
effluent samples. Composite sample collection time is documented pn the Total Suspended
bench worksheet, but is not clear or adequate to meet administrative code requirements. p Solids
Recommendation: Recommend the development of a sample collection document or chain -of -custody
form to record required sampling and preservation information.
Requirement: A record of date collected, time collected, sampler, collector, and preservatives must be maintained. ref: 15A NCAC 2H .0805 (a)(7)(M) pg. 7.1
use of proper
6) Violation: Control limits have not been established for duplicate sampleresults in the Quality
Control Quality Assurance Program document and relative percent difference (RPD) is not calculated
and documented for duplicate analytical results. Corrective action procedures have not been clearly
defined for RPDs outside control limits. Duplicate values reviewed were within guidelines established
in Table 1020:1 in Standard Methods for the Examination of Water and Wastewater, 18th edition.

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Requirement: If duplicate results indicate a problem, statistical control, limits must be established as
set forth in Standard Methods 1020B and 1030C and three standard deviations used to determine if
data is acceptable. Any time quality control results indicate an analytical,problem, the problem must be
resolved and any samples involved must be reanalyzed if the holding time has not expired. Reference:
15A NCAC 2H .0805 (a) (7) (F). Table 1020:1 in Standard Methods for thej Examination of Water and
Wastewater, 18`h edition may be used as a guide to determine whether the analysis of duplicates
indicates an analytical problem.
7) Violation: Specific requirements from the Administrative Code 15A NCAC 2H .0800 dated 2/2/94
have not been incorporated into the laboratory's Quality Control D4ocunient or Standard Operating
Procedures.
Comment: Six sections of the administrative code cited in this report, were either not addressedin
this document or were not effectively implemented. P
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) pg. 6. Please submit a copy of the revised quality control document to this office for review.
Highlight or index the sections relating to administrative code requirements. 1
IV. DATA REVIEW:
Data review consisted of a review of the Chain of Custody procedure' for North Carolina
Wastewater/Groundwater samples to check for adherence to required preservation and hold times.
Bench sheets and analytical reports for randomly selected dates fron( January 1998 through
November 1998 were reviewed and compared to Discharge Monitoring, Reports for the parameters
on the laboratory's discharge permit number NC0005321. No problems in properly calculating or
transcribing data were detected.
V. CONCLUSION:
Seven violations were cited. Four of the violations cited relate to four supplemental requirements of
the Laboratory Certification Program Administrative Code 15A NCAC 2H .0800. The laboratory's
analytical quality assurance document must be updated to incorporate administrative code
requirements. Three violations cited are method requirements which must be included in the
standard operating procedure for the specific analyses. Lab must submit evidence of corrective
actions taken for all violations. Please submit a reply to all comments and recommendations.
Correction of the above cited violations should help this lab document the quality of data produced,
and meet,North Carolina certification requirements.
Report prepared by: Harvi C. Cooper
Date: December 28, 1998
Report reviewed by: Norman L. Good
Date: February 18, 1999