#184_07_2015_FINAL

184
Mr. Stephen DiPiero
'Weyerhaeuser NR Company Environmental Lab
1785 Weyerhaeuser Rd
Vanceboro, NC 28586
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. DiPiero:
Enclosed is a report for the inspection performed on July 15, 2015 by Nick Jones. No findings are
cited in this report, a response is not required. We appreciate the fine job you and your staff are
doing. As a certification requirement, 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
Nick Jones
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] t FAX: [phone]
Internet: www.dwpiab.org
An Equal Opportunity 1 A.rfirmative Action Employer

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
184
Laboratory Name:
Weyerhaeuser NR Company Environmental Lab
Inspection Type:
Industrial Maintenance
Inspector Name(s):
Nick Jones
Inspection Date:
July 15, 2015
Date Report Completed:
August 24, 2015
Date Forwarded to Reviewer:
August 24, 2015
Reviewed by:
Todd Crawford
Date Review Completed:
August 24, 2015
Cover Letter to use:
❑ Insp. Initial ❑ Insp. Reg.
❑ Insp. No Finding ❑ Insp. CID
® Corrected
Unit Supervisor/Chemist III:
Gary Francies
Date Received:
8/26/2015
Date Forwarded to Linda:
9/10/2015
Date Mailed:
9/11/2015 ��

LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
INTRODUCTION:
On -Site Inspection Report
Weyerhaeuser NR Company Environmental Lab
NC0003191
1785 Weyerhaeuser Rd
Vanceboro, NC 28586
184
July 15, 2015
Industrial Maintenance
Nick Jones
Stephen DiPiero, Garey Dunn and Lynn Adams
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.
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 2015
proficiency testing calendar year and the graded results were 100% acceptable.
The laboratory is reminded that any time changes are made to laboratory operations; the
laboratory must update the Quality Assurance (QA)/Standard Operating Procedures (SOP)
document(s). Any changes made in response to the Findings, Recommendations or Comments
listed in this report must be incorporated to insure the method is being performed as stated,
references to methods are accurate, and the QA and/or SOP document(s) is in agreement with
approved practice and regulatory requirements. In some instances, the laboratory may need to
create a SOP to document how new functions or policy will be implemented.
Contracted analyses are performed by Environment 1, Inc. (Certification #10).
FINDINGS. REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
Comment: The laboratory did not have an Analytical Quality Control Document or Standard
Operating Procedure (SOP) for Proficiency Testing. The North Carolina Administrative Code, 15A
NCAC 2H .0805 (a) (7) states: 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. The
NC WW/GW Proficiency Testing Requirements document, February 20, 2012, Revision 1.2.
states: Laboratories must have a documented plan (this is usually detailed in the laboratory's Quality
Assurance Manual) of how they intend to cover the applicable program requirements for proficiency
testing per their scope of accreditation. This plan shall cover any commercially available proficiency

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#184 Weyerhaeuser NR Company Environmental Lab
testing and any inter -laboratory organized studies, as applicable. The laboratory must also be able to
explain when proficiency testing is not possible for certain parameters and provide a description of
what the laboratory is doing in lieu of proficiency testing. This shall be detailed in the plan. The plan
must also address the laboratory's process for submission of proficiency testing results and related
corrective action responses. Laboratory Standard Operating Procedures (SOPs) must address how
low level samples will be analyzed, including concentration of the sample or adjustment of the
normality of a titrant. These instructions shall be followed when the concentration of a PT sample
falls below the range of their routine analytical method. Instructions shall also be included in the
laboratory's SOP for how high level samples will be analyzed, including preparation of multiple
dilutions of the sample. These instructions will be followed when the concentration of a PT falls
above the range of their routine analytical method. Demonstration of acceptable corrective actions
(i.e., an acceptable Proficiency Testing SOP with an implementation date of 8/21/2015), was
provided via email on 8/20/2015. No further response is necessary for this Finding.
Comment: The Standard Operating Procedures (SOPs) did not document all necessary quality
control practices, the SOP(s) were in direct conflict with method and/or regulatory requirements,
and/or did not describe in sufficient detail how the method is performed (observations are listed
below). The North Carolina Administrative Code, 15A NCAC 2H .0805 (a) (7) states: 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. Demonstrations of acceptable corrective actions
(i.e., revised SOPs with corrections for the items listed below with an implementation date of
8/21/2015), were provided via email on 8/20/2015, 8/31/2015, and 9/1/2015. No further response is
necessary for this Finding.
• pH (SM 4500-H+ B-2000)
o The SOP does not state the complete method of reference (i.e., the Standard
Methods Committee approval year was missing from the SM 4500-H+ B-2000
reference method) and an unapproved method was referenced (i.e., USEPA 600/4-
79-020, 1979, Methods for Chemical Analysis of Water and Waste).
• Dissolved Oxygen (SM 4500-0 G-2001)
o The SOP does not state the method of reference.
• Color, Platinum Cobalt (SM 2120 B-2001)
o The SOP does not state the method of reference.
o The SOP states that pH adjustment cannot change the volume of the sample by
more than 5%. The method states 3%.
• Conductivity (EPA 120.1, Rev. 1982)
o The SOP does not state the complete method of reference. It did state: USEPA
60014-79-020, 1982, Methods for Chemical Analysis of Water and Wastewater.
Method 120.1 Specific Conductance, pmhos at 25T. The revision years of USEPA
600/4-79-020 were 1983 and 1979. The EPA 120.1 method year is 1982.
o The SOP does not mention preservation temperature.
Chemical Oxygen Demand (SM 5220 D-1997)
o The SOP does not state the correct method of reference or the method for which
the lab is certified. It states Hach 8000.
o The SOP does not state the calibration curve (i.e., preparation, concentration,
levels, and acceptance criteria).
o The SOP does not state the sample is preserved to a pH of <2 s.u.

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#184 Weyerhaeuser NR Company Environmental Lab
Biochemical Oxygen Demand (SM 5210 B-2001)
o The SOP does not state preservation temperature.
o The SOP does not state that the buffer solutions have a six month expiration date.
o The SOP does not include the seed preparation procedure.
o The SOP states that the dilution water is aerated. The analysts stated that this is not
practiced.
o The SOP does not state that the initial DO of the blank must to be between 7.5 and
9.0 mg/L.
o The SOP does not state that the initial DO of all bottles other than the blank must be
between 7 and 9 mg/L.
o The SOP does not state that all dilutions for samples and seed controls which
deplete at least 2.0 mg/L DO and have at least 1.0 mg/L DO remaining are
averaged for the final BOD result.
o The SOP does not state that the GGA results are averaged.
o The SOP does not state the calculations for sample and GGA results.
o The SOP does not state the acceptance criterion for the duplicate analyses.
• Residue Suspended (SM 2540 D-1997)
o The SOP does not state the complete method of reference. It did state: Standard
Methods for the Examinations of Water and Wastewater, current edition, 2540D.
The Standard Methods Committee approval year (i.e., 1997) was not listed.
Proficiencv Testin
Comment: The laboratory's common practice was to analyze known standards along with the
Proficiency Testing (PT) samples as additional quality control. The Proficiency Testing
Requirements document, February 20, 2012, Revision 1.2. states: All PT samples are to be
analyzed and the results reported in a manner consistent with the routine analysis and reporting
requirements of compliance samples and any other samples analyzed according to the
requirements of 15A NCAC 2H .0800. 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 from now on PT samples will be analyzed in the same manner as environmental
samples), was received via email on 8/17/2015. No further response is necessary for this
Finding.
Comment: The laboratory was not documenting Proficiency Testing (PT) samples in the same
manner as compliance samples. The Proficiency Testing Requirements document, February 20,
2012, Revision 1.2. 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 from now on PT samples will be
documented in the same manner as environmental samples), was received via email on 8/17/2015.
No further response is necessary for this Finding.
Chemical Oxnen Demand — Standard Methods, 5220 D-1997
Comment: The laboratory was not analyzing a Laboratory Fortified Matrix (LFM) and/or Laboratory
Fortified Matrix Duplicate (LFMD) at the required frequency. Standard Methods 4020 B-2009, Rev.
2011, Table 4020:1 and (2) (g) states: Include at least one LFM/LFMD daily or with each batch of 20
or fewer samples. Notification of acceptable corrective actions (i.e., a statement that the SOP for
COD was revised to include a LFM and LFMD on 8/4/15 and a statement that changes to lab
testing will be fully implemented by 8/28/15), was received via email on 8/5/2015. No further
response is necessary for this Finding.

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Color, Platinum Cobalt — Standard Methods, 2120 B-2001
Chemical Oxygen Demand — Standard Methods, 5220 D-1997
Comment: The lab was not analyzing a calibration blank and calibration verification standard after
every ten samples and at the end of each analysis batch. Standard Methods 2020 B-2009, Rev.
2011, Table 2020:11 and (2) (b) and Standard Methods 5020 B-2009, Rev. 2011, Table 5020:1 and
(2) (b) state: Verify calibration by periodically analyzing a calibration standard and calibration blank
during a run —typically, after each batch of ten samples and at the end of the run. Notification of
acceptable corrective actions (i.e., a statement that the SOPs for COD and Color were revised to
include the analysis of calibration verification standards and calibration blanks after every ten
samples and at the end of the run on 8/4/15 and a statement that changes to lab testing will be
fully implemented by 8/28/15), was received via email on 8/5/2015. No further response is
necessary for this Finding.
Biochemical Oxygen Demand — Standard Methods, 5210 B-2001
Comment: Samples were not properly adjusted for pH. Standard Methods, 5210 B-2001 (4) (b) (1)
states: Check pH; if it is not between 6.0 and 8.0, adjust sample temperature to 20 ± 3 °C, then
adjust pH to 7.0 to 7.2 using a solution of sulfuric acid or sodium hydroxide of such strength that
the quantity of reagent does not dilute the sample by more than 0.5%. The pH of dilution water
should not be affected by the lowest sample dilution. Always seed samples that have been pH
adjusted. Notification of acceptable corrective actions (i.e., a statement that the SOP for BOD was
revised to include the adjustment of sample pH to within 7.0 and 7.2 s.u. when sample pH is not
within 6.0 and 8.0 s.u. on 8/4/15, and a statement that changes to lab testing will be fully
implemented by 8/28/15), was received via email on 8/5/2015. No further response is necessary
for this Finding.
Residue, Suspended — Standard Methods, 2540 D-1997
Comment: The laboratory needed to increase the documentation of traceability of purchased
materials. NC WW/GW LC Policy 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 (where specified This information as
well as the vendor and/or manufacturer, lot number, and expiration date must be retained for
primary standards, chemicals, reagents, and materials used for a period of five years.
Consumable materials such as pH buffers, lots of pre -made standards and/or media, solids and
bacteria filters, etc. are included in this requirement. Demonstration of acceptable corrective action
(i.e., suspended residue filter information was added to the lab's existing traceability log), was
performed during the inspection. No further response is necessary for this Finding.
Comment: The laboratory is not basing the reporting limit on the minimum weight gain required
by the method. Standard Methods, 2540 D-1997 (3) (b) states: Choose sample volume to yield
between 2.5 and 200 mg dried residue. If volume filtered fails to meet minimum yield, increase
sample volume up to 1 L. NC WW/GW LC Policy states: Choose sample volume to yield between
2.5 and 200 mg dried residue. To obtain the required residue yield, successive aliquots of
samples may be added to the same dish after evaporation or adjust reporting level based upon
the weight gain and sample volume used. The minimum reporting value is established at 2.5 mg/L
based upon a sample volume used of 1000 mL. This requirement is a new policy that has been
implemented by our program since the last inspection. Notification of acceptable corrective actions
(i.e., a statement that the benchsheet for TSS was revised to include the proper adjustment of the
Practical Quantitation Limit (PQL) Based upon the sample volume and minimum weight gain on
8/4/15 and a statement that changes to lab testing will be fully implemented by 8/28/15), was
received via email on 8/5/ 2015. No further response is necessary for this Finding.

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Comment: The 1 hour drying time was not always documented. The analysts did not always fill out
the space on the benchsheet designated for "Time Out" of the drying oven. Standard Methods, 2540
D-1997 states: Dry for at least 1 h at 103 to 105°C in an oven, cool in a desiccator to balance
temperature, and weigh. The North Carolina Administrative Code, 15A NCAC 2H .0805 (a) (7) (a)
states: All analytical data pertinent to each certified analysis must be filed in an orderly manner so as
to be readily available for inspection upon request. Notification of acceptable corrective actions (i.e.,
a statement to monitor these benchsheets for the next three months to ensure complete
documentation of drying time), was provided via email on 8/28/2015. No further response is
necessary for this Finding.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North
Carolina Division of Water Resources. Data were reviewed for Weyerhaeuser NR Company
Environmental Lab (NPDES permit # NC0003191) for June, 2015. No transcription errors were
detected. The facility appears to be doing a good job of accurately transcribing data.
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: Nick Jones Date: August 24, 2015
Report reviewed by: Todd Crawford Date: August 24, 2015