#5646_12_2014_FINAL

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North Carolina Department of Environment and Natural Resources
Pat McCrory Donald R. van der Vaart
Governor Secretary
January 26, 2015
5646
Mr. Mario Sainz
Horsehead Metal Products
484 Hicks Grove Road
Mooresboro, NC 28114
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Sainz:
Enclosed is a report for the inspection performed on December 17, 2014 by Jason Smith. 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. 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 (828)
296-4677.
Attachment
cc: Master file
Jason Smith
Sincerely,
COY
Gary Francies, Technical Assistance/Compliance Specialist
Division of Water Resources
Water Sciences Section
NC wastewater/Groundwater Laboratory Certification Branch
1623 Mall Service Center, Raleigh, North Carolina 27699-1623
Location: 4405 Reedy Creek Road, Raleigh, North Carolina 27607
Phone!919-733-390U FAX:[phone]
Internet: www.dwglab.orq
An Equal Opportunity) Affirmative Action Employer

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5646
Laboratory Name:
Horsehead Metal Products
Inspection Type:
Field Initial
Inspector Name(s):
Jason Smith
Inspection Date:
December 17, 2014
Date Report Completed:
January 16, 2015
Date Forwarded to Reviewer:
January 16, 2015
Reviewed by:
Nick Jones
Date Review Completed:
January 20, 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 /20/2015
Date Forwarded to Linda: 1/23/2015
Date Mailed: \ 1131 '� 5 1 _c

LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
On -Site Inspection Report
Horsehead Metal Products
NCO089109
484 Hicks Grove Road
Mooresboro, NC 28114
5646
December 17, 2014
Field Initial
Jason Smith
LOCAL PERSON(S) CONTACTED: Mario Sainz, Jim Harris, Casey McMahon, Ron Gilbert, and Charlie Howell
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. 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 Pace Analytical Services, Inc. Asheville (Certification #40).
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
A. Finding: Some instances of improper error corrections were observed.
Requirement: 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. Ref: Quality Assurance Policies for
Field Laboratories.

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#5646 Horsehead Metal Products
B. Finding: The laboratory needs to increase the documentation of purchased materials and
reagents.
Requirement: 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. Consumable materials such as pH buffers and lots
of pre -made standards are included in this requirement. Ref: Quality Assurance Policies for
Field Laboratories.
C. Finding: Units of measure (Standard Units or S.U.) are not documented on the benchsheet and
calibration log.
Requirement: The field benchsheets must provide a space for the signature or initials of the
analyst, and proper units of measure for all analyses. Ref: 15A NCAC 2H .0805 (g) (1).
D. Finding: The true values of the 4 S.U. and 10 S.U. buffers are not documented on the calibration
log.
Requirement: The following must be documented in indelible ink whenever sample analysis is
performed: True values of buffers used for calibration. Ref: NC WW/GW LC Approved Procedure
for the Analysis of pH.
E. Finding: Sample collection and analysis times are not documented.
Requirement: Data pertinent to each analysis must be maintained for five years. Certified Data
must consist of date collected, time collected, sample site, sample collector, and sample analysis
time. The field benchsheets must provide a space for the signature or initials of the analyst, and
proper units of measure for all analyses. Ref: 15A NCAC 02H .0805 (g) (1).
Comment: The time of receipt in the laboratory was documented. This is not required. Collection
and analysis times are required in order to demonstrate that the fifteen minute holding time was
met.
pH — Standard Methods, 4500 H+ B-2000
F. Finding: The facility does not report all the data as required.
Requirement: The results of all tests on the characteristics of the effluent, including but not
limited to NPDES permit monitoring requirements, shall be reported on the monthly report
forms. Ref: 15A NCAC 26 .0506 (b) (3) (J).
Comment: The laboratory analyzes pH samples daily, but only reports one value each week as
required for their permit.
Comment: The laboratory analyzes effluent pH samples every two hours every day. The pH
values are averaged. Since pH is a logarithmic value, these results are not allowed to be
averaged.
Recommendation: It is recommended that the laboratory analyze pH samples for process control
by collecting them prior to the final effluent. These values are not required to be reported on the
Discharge Monitoring Report. Process control samples need to be clearly labeled as such on the
benchsheet.

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#5646 Horsehead Metal Products
IV. 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 Horsehead Metal Products (NPDES permit #NC0089109) for September and October,
2014. No transcription errors were detected. The facility appears to be doing a good job of accurately
transcribing data.
V. CONCLUSIONS:
Correcting the above -cited findings and implementing the recommendation 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.
Report prepared by: Jason Smith Date: January 16, 2015
Report reviewed by: Nick Jones Date: January 20, 2015