#5023_12_2014_FINAL

January 13, 2015
5023
Mr. Rodney Willis
FMC Corporation, Lithium Division
P.O. Box 795
Bessemer City, NC 28016
Jahn E. Skvarla, III
Secretary
SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Willis:
Enclosed is a report for the inspection performed on December 10, 2014 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 [phone].
Attachment
cc: Master file
Jason Smith
Sincerely,
Gary Francies, Technical Assistance/Compliance Specialist
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] ! FAX: [phone]
Internet: www.dwalab.orq
An Equal OppodunilyiAffirmative Action Employer

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5023
Laboratory Name:
FMC Corporation, Lithium Division
Inspection Type:
Field Maintenance
Inspector Name(s):
Jason Smith
_Inspection Date:
December 10, 2014
Date Report Completed:
January 7, 2015
Date Forwarded to Reviewer:
January 7, 2015
Reviewed by:
Beth Swanson
Date Review Completed:
January 7, 2015
Cover Letter to use:
❑ Insp. Initial ❑ Insp. Reg.
❑ Insp. No Finding ❑ Insp. CP
® Corrected ❑ Insp. Reg. Delay
Unit Supervisor/Chemist III:
Gary Francies
Date Received:
1 /7/2015
Date Forwarded to Linda:
1/12/2015
Date Mailed:
1/13/2015 LC
please send to Wes Bell in MRO wes.bell(a)ncdenr.gov

On -Site Inspection Report
LABORATORY NAME: FMC Corporation, Lithium Division
NPDES PERMIT #: NC0005177
ADDRESS: P.O. Box 795
Bessemer City, NC 28016
CERTIFICATE #: 5023
DATE OF INSPECTION: December 10, 2014
TYPE OF INSPECTION: Field Maintenance
AUDITOR(S): Jason Smith
LOCAL PERSON(S) CONTACTED: Rodney Willis
I. 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:
The facility has all the equipment necessary to perform the analyses. Proficiency Testing (PT) samples
have been analyzed for all certified parameters for the 2014 proficiency testing calendar year and the
graded results were 100% acceptable.
Contracted analyses are performed by Pace Analytical Services, Inc. Huntersville (Certification #12).
Current quality assurance policies for Field Laboratories and approved procedures for the analysis of
the facility's currently certified parameters were provided at the time of the inspection.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
Comment: Error corrections were not dated. The 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. This requirement is a new policy that has been implemented by our
program since the last inspection. Notification of acceptable corrective action (i.e., a statement that
error corrections are dated when made beginning December 10, 2014) was received by email on
January 7, 2015. No further response is necessary for this finding.

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*5023 FMC Corporation, Lithium Division
Comment: The laboratory needed to increase the documentation of purchased materials and
reagents. The Quality Assurance Policies for Field Laboratories document states: 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
requirement is a new policy that has been implemented by our program since the last inspection.
Notification of acceptable corrective action (i.e., a statement that a traceability log that contains spaces
to enter the date received, date opened (in use), vendor, lot number and expiration date for purchased
materials and reagents emailed to the facility on January 7, 2015 has been put into use) was received
by email on January 7, 2015. No further response is necessary for this finding.
Proficiency Testing
Comment: The laboratory was not documenting PT sample analyses in the same manner as
environmental samples. The Proficiency Testing Requirements, February 20, 2012, Revision 1.2
document states: All PT sample analyses must be recorded in the daily analysis records as for any
environmental sample. This serves as the permanent laboratory record. This requirement is a new
policy that has been implemented by our program since the last inspection. Notification of acceptable
corrective action (i.e., a statement that the results of PT samples will be recorded on the "Monthly
Sampling Schedule Log" sheet and filed with PT report) was received by email on January 7, 2015. No
further response is necessary for this finding.
Conductivity —Standard Methods, 2510 B-1997
Comment: The meter was not being calibrated daily (the meter was checked with a 1000 pS/cm
Conductivity standard daily and recalibrated if it was not within 20 pS/cm of the true value). The NC
WW/GW LC Approved Procedure for the Analysis of Specific Conductance (Conductivity) document
states: Instruments are to be calibrated according to the manufacturer's calibration procedure prior to
analysis of samples each day compliance monitoring is performed For most meters, this is a one point
calibration. After calibration, analyze and document a calibration verification check standard prior to
environmental sample analysis. It is recommended that this standard value bracket (may be higher or
lower than the calibration standard, as applicable) the expected range of sample values measured. The
value obtained for the calibration verification check standard must read within 10% of the true value of the
calibration verification check standard. If the obtained value is outside of the ±10% range, corrective
action must be taken. Notification of acceptable corrective action (i.e., a statement that the laboratory
began calibrating the Conductivity meter daily beginning December 10, 2014) was received by email on
January 7, 2015. No further response is necessary for this finding.
Comment: The Automatic Temperature Compensator (ATC) of the meter was not checked every 12
months (performed December 4, 2014 and last checked June 19, 2013). The NC WW/GW LC Approved
Procedure for the Analysis of Specific Conductance (Conductivity) document states: The Automatic
Temperature Compensator (ATC) must be verified annually (i.e., 12 months) at two temperatures by
analyzing a standard or sample at 250C (the temperature that conductivity values are compensated to)
and a temperature(s) that brackets the temperature ranges of the environmental samples routinely
analyzed. This may require the analysis of a third temperature reading that is > 25°C. Notification of
acceptable corrective action (i.e., a statement that the analyst made a recurring annual reminder which
is also copied to the backup ORC to perform the ATC check as required) was received by email on
January 12, 2015. No further response is necessary for this finding.

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#5023 FMC Corporation, Lithium Division
W
PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing field testing records and contract lab reports to Discharge
Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Resources. Data were
reviewed for January, February, and October, 2014. The following error was noted:
Date
Parameter
Location
Value on Benchsheet
Value on DMR
10/8/14
Conductivity
Effluent
1304 pS/cm
No value reported
The laboratory submitted an amended DMR to correct this omission on December 24, 2014.
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.
Report prepared by: Jason Smith
Report reviewed by: Beth Swanson
Date: January 7, 2015
Date: January 7, 2015