#5173_2019_0821_MC_FINAL

Laboratory Cert. #:
5173
Laboratory Name:
Innospec Performance Chemicals
Inspection Type:
Field Industrial Maintenance
Inspector Name(s):
Michael Cumbus, Beth Swanson
Inspection Date:
August 21, 2019
Date Forwarded for Initial
Review:
August 28, 2019
Initial Review by:
Tonja Springer
Date Initial Review
Completed:
September 9, 2019
Cover Letter to use:
❑ Insp. Initial
❑Insp. No Finding
❑Corrected
® Insp. Reg
❑Insp. CP
❑Insp. Reg. Delay
Unit Supervisor/Chemist III:
Beth Swanson
Date Received:
9/9/2019
Date Forwarded to Admin.:
9/11/2019
Date Mailed:
9/13/2019
Special Mailing Instructions:

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Mr. Allen Robey
Innospec Performance Chemicals
510 Hinkle Lane
Salisbury, NC 28144-
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r vr`rov menta t Quality
September 13, 2019
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Robey:
Enclosed is a report for the inspection performed on August 21, 2019 by Michael Cumbus and Beth
Swanson. 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.
Please describe the steps taken to prevent recurrence 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.
A copy of the laboratory's Certified Parameter List at the time of the audit is attached. This list will reflect
any changes made during the audit. 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 me at [phone] Ext. 259.
Attachment
cc: Dana Satterwhite
Sincerely,
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5atr
Beth Swanson
Technical Assistance & Compliance Specialist
Division of Water Resources
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North Carolina Department of Environmental Quality I Division of Water Resources
1623 Mail Service Center I Raleigh, North Carolina 27699-1.623
Phone [phone]/Fax [phone]

CERTIFICATE :
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Innospec Performance Chemicals
WQ0001077
510 Hinkle Lane
Salisbury, NC 28144
5173
August 21, 2019
Field Industrial Maintenance
Michael Cumbus and Seth Swanson
LOCAL PERSON(S) CONTACTED: Allen Robey and Roxanne Fincher
This laboratory was inspected by representatives 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.
The facility is neat and well organized and has all the equipment necessary to perform the
analyses. Records are well organized and easy to retrieve. Staff were forthcoming and seemed
eager to adopt necessary changes. Laboratory documentation, however, was incomplete, and
additional quality control procedures need to be implemented.
All required Proficiency Testing (PT) Samples for the 2019 PT Calendar Year have not yet been
received. The laboratory is reminded that results must be received by this office directly from the
vendor by September 30, 2019.
The laboratory does not yet have Quality Assurance (QA) and/or Standard Operating
Procedures (SOP) documents in place. Personnel were informed that while these documents
are not required to be submitted, they must be in place by July 1, 2020. A documented training
program must be implemented by August 1, 2020.
Requirements that reference 15A NCAC 2H .0805 (g) (1), stating "All analytical records, including
original observations and information necessary to facilitate historical reconstruction of the

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#5173 Innospec Performance Chemicals
calculated results, shall be maintained for five years," It is not intended to imply that existing
records are not adequately maintained unless the Finding speaks directly to that.
Contracted analyses are performed by Statesville Analytical Holdings, LLC (Certification # 440).
Documentation
Comment: It was noted during the inspection that the laboratory may record the facility name,
permit number, method reference and instrument identification once on the cover or inside the
front cover of the laboratory notebook, provided that any changes are clearly described and dated.
A. Finding: The laboratory benchsheet for pH is lacking pertinent data: time of sample
collection, facility name, method reference, instrument identification, analyst's name or
initials and units of measure.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses and shall consist of: the time of
sample collection, facility name, method reference, instrument identification, analyst's
name or initials and units of measure. Ref: 15A NCAC 2H .0805 (g) (2) (A), (B), (C), (E),
(F) and (Q.
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: time of sample collection, facility name, method reference,
instrument identification (serial number preferred), collector's/analyst's name or initials and
units of measure. Ref: NC WW/GW LC Approved Procedure for the Analysis of pH.
Comment: While the laboratory benchsheet did have the units of measure, the calibration
log for the pH meter, which is recorded in a different location, was lacking the units of
measure.
B. Finding: The laboratory benchsheet for pH is lacking pertinent data: meter calibration
time, permit number.
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: meter calibration time and permit number. Ref: NC WW/GW LC
Approved Procedure for the Analysis of pH.
C. Finding: The laboratory needs to document traceability information of purchased
materials and reagents.
Requirement: All analytical records, including original observations and information
necessary to facilitate historical reconstruction of the calculated results, shall be
maintained for five years. Ref: 15A NCAC 2H .0805 (g) (1).
Requirement: Chemical containers shall be dated when received and when opened.
Reagent containers shall be dated, identified, and initialed when prepared. Chemicals
and reagents exceeding the expiration date shall not be used. Chemicals and reagents
shall be assigned expiration dates by the laboratory if not given by the manufacturer. If
the laboratory is unable to determine an expiration date for a chemical or reagent, a
one-year time period from the date of receipt shall be the expiration date unless
degradation is observed prior to this date. The laboratory shall have a documented

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#5173 Innospec Performance Chemicals
system of traceability for all chemicals, reagents, standards, and consumables. Ref: 15A
NCAC 2H .0805 (g) (7).
Comment: Dates received and opened were written on the pH buffer bottles. While this
can provide a traceability link to analyses by looking at the dates that the chemicals were
in use, that link is lost once the bottles are discarded. A reagent receipt log was provided
to the laboratory at the time of inspection.
D. Finding: Non -Compliance data is not documented as such.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses and shall consist of: sample
identification. Ref: 15A NCAC 2H .0805 (g) (2) (1).
Comment: The laboratory is not consistent in its use of the word "effluent" to describe the
compliance sample site. Prior to July 1, 2019 the laboratory was using descriptors "left",
"right" and "effluent", with "effluent" referring to compliance data from analysis of the spray
irrigation samples. Since July 1, 2019, the laboratory has been using the descriptor
"effluent" to refer to samples which are analyzed from the discharge into the municipal
sewer system and is not compliance data. As an example, for samples collected on July
18, 2019, the value recorded for pH on the DMR was 7.65 S.U., while the laboratory
benchsheet listed an effluent with a value of 7.2 S.U. The WWTP daily log listed a pH of
7.65 S.U. The laboratory must come up with a system that uniquely identifies sample sites
that describes them as the compliance versus non-compliance data so as to avoid
questions of data integrity.
Proficiency iesting
E. Finding: The laboratory is not documenting PT Sample analyses in the same manner as
routine Compliance Samples.
Requirement: All PT Sample analyses must be recorded in the daily analysis records as
for any Compliance Sample. This serves as the permanent laboratory record. Ref:
Proficiency Testing Requirements, October 29, 2018, Revision 3.
Requirement: The laboratory shall retain all records necessary to facilitate historical
reconstruction of the analysis and reporting of analytical results for PT Samples. This
means the laboratory must have available and retain for five years [pursuant to 15A NCAC
2H .0805 (g) (1)] all of the raw data, including benchsheets, instrument printouts and
calibration data, for all PT Sample analyses and the associated QC analyses conducted
by all parameter methods. Ref: Proficiency Testing Requirements, October 29, 2018,
Revision 3.
Comment: The laboratory was documenting the calibration of the pH meter and the PT
results on the reporting sheet that accompanies PT samples, rather than in the laboratory
notebook where routine compliance samples are recorded.
F. Finding: PT Samples have not been distributed among all analysts from year to year.
Requirement: Laboratories shall also ensure that, from year to year, PT Samples are
equally distributed among personnel trained and qualified for the relevant tests and
instrumentation (when more than one instrument is used for routine Compliance Sample
analyses), that represents the routine operation of the work group at the time the PT

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#5173 Innospec Performance Chemicals
Sample analysis is conducted. Ref: Proficiency Testing Requirements, October 29, 2018,
Revision 3.
G. Finding: The laboratory is not analyzing a check standard buffer after calibration and prior
to sample analysis.
Requirement: Instruments are to be calibrated according to the manufacturer's calibration
procedure prior to analysis of samples each day compliance monitoring is performed.
Calibration must include at least two buffers. The meter calibration must be verified with a
third standard buffer solution (i.e., check buffer) prior to sample analysis. Ref: NC
WW/GW LC Approved Procedure for the Analysis of pH.
Comment: The laboratory is calibrating with 3 buffers with true values of 4.0, 7.0 and 10.0
S.U.
H. Finding: Values were reported that exceed the method specified accuracy of 0.1 units.
Requirement: By careful use of a laboratory pH meter with good electrodes, a precision
of ±0.02 unit and an accuracy of ±0.05 unit can be achieved. However, ± 0.1 pH unit
represents the limit of accuracy under normal conditions, especially for measurement of
water and poorly buffered solutions. For this reason, report pH values to the nearest 0.1
H unit. Ref: Standard Methods, 4500 H+ B-2011. (6).
Recommendation: It is recommended that the laboratory continue to record pH data to
0.01 S.U. but report pH data to the nearest 0.1 S.U. on the Non -Discharge Monitoring
Reports (NDMRs).
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) and contract lab reports to NDMRs submitted to the North Carolina Division of Water
Resources. Data were reviewed for Innospec Performance Chemicals (Water Quality permit #
WQ0001077) for July 2019, February 2019 and November 2018. No transcription errors were
observed. The facility appears to be doing a good job of accurately transcribing data.
Correcting the above -cited Findings and implementing the Recommendations will help this
laboratory to produce quality data and meet Certification requirements. The inspector would like
to thank the staff for their assistance during the inspection and data review process. Please
respond to all Findings and include supporting documentation, implementation dates
and steps taken to prevent recurrence for each corrective action.
Report prepared by: Michael Cumbus Date: August 28, 2019
Report reviewed by: Tonja Springer Date: September 9,
2019

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