#555 - 03 - 2012 - FINAL

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
555
Laboratory Name:
Unimin Schoolhouse Quartz Plant
Inspection Type:
Industrial Maintenance
Inspector Name(s):
Jason Smith
Inspection Date:
March 27 2012
Date Report Completed:
April 18, 2012
Date Forwarded to Reviewer: April 18, 2012
Reviewed by:
Todd Crawford
Date Review Completed:
April 19, 2012
Cover Letter to use: _
Insp. Initial X Insp. Reg. _ Insp. No Finding _ Insp. CP _ Corrected
Unit Supervisor:
Gary Francies
Date Received:
4/27/2012
Date Forwarded to Linda:
5/15/2012
Date Mailed:
.

Beverly Eaves Perdue
Governor
555
Mr. Scott Fortner
Unimin Quartz Schoolhouse Plant
P.O. Box 588
Spruce Pine, NC 28777
a •'NCDENR
Division of Water Quality
Charles Wakild, P. E.
Director
May 16, 2012
Dee Freeman
Secretary
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW
LC) Maintenance Inspection
Dear Mr. Fortner.:
Enclosed is a report for the inspection performed on March 27, 2012 by Jason Smith. I
apologize for the delay in getting this report to you. 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.
Sincerely,
ca�� �Z'4� 4-0-kl
Gary Francies
Certification Unit Supervisor
Laboratory Section
Enclosure
cc: Jason Smith
Master File
DENR DWO Laboratory Section NC Wastewater/Groundwater Laboratory Certification Branch
1623 Mail Service Center, Raleigh, North Carolina-27699-1623
Location: 4405 Reedy Creek Road. Raleigh, North Carolina 27607-6445
Phone: [phone] t FAX: [phone]
Internet: www.dwglab.org
One
Northfarolina
An Equal Opportunity 1 Affirmative Action Employer

LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
INTRODUCTION:
On -Site Inspection Report
Unimin Quartz Schoolhouse Plant
NC0000361
P.O. Box 588
Spruce Pine, NC 28777
555
March 27, 2012
Industrial Maintenance
Jason Smith
Scott Fortner
This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for
the analysis of environmental samples.
GENERAL COMMENTS:
Laboratory personnel changed since the last inspection. The inspector is concerned about the number of
transcription errors and record omissions detected during the data review process. Many of the data
points recorded on the benchsheet did not compare to the values reported on the Discharge Monitoring
Reports (DMRs). These observations are documented in the Paper Trail Investigation section of this
report.
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.
The requirements associated with Findings B, C, D and E are new policies that have been implemented
by our program since the last inspection.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
General Laboratory
Comment: The laboratory was not documenting the required information for purchased chemicals. North
Carolina Wastewater/Groundwater Laboratory Certification 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). A
system (e.g., traceable identifiers) must be in place that links standard/reagent preparation information

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#555 Unimin Schoolhouse Quartz Plant
to analytical batches in which the solutions are used. Documentation of solution preparation must
include the analyst's initials, date of preparation, the volume or weight of standard(s) used, the solvent
and final volume of the solution. 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., the analyst located the traceability log and stated that it would be
put into use immediately) was performed at the time of the inspection. No further response is
necessary for this finding.
A. Finding: The analyst was not able to locate the laboratory Standard Operating Procedures
(SOPS).
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. The quality
control document shall be available for inspection by the State Laboratory. Ref: 15A NCAC 2H
.0805 (a) (7). Please submit a copy of all laboratory SOPs by December 31, 2012.
B. Finding: When duplicate analyses are performed, the laboratory only reports the first result
obtained.
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 monthly report forms.
Ref: 15A NCAC 02B .0506 (3) (J).
Comment: This is no longer allowed as it was in the past. In order to fulfill the requirements of this
Rule, the laboratory must either report the average of the results or report both results on the
Discharge Monitoring Report (DIVIR).
C. Finding: Proficiency Testing (PT) samples were not analyzed in the same manner as routine
environmental samples.
Requirement: The analysis of PT samples is designed to evaluate the entire process used to
routinely report environmental analytical results; therefore, PT samples must be analyzed and
the process documented in the same manner as environmental samples. Ref: Proficiency
Testing Requirements, February 20, 2012, Revision 1.2.
Comment: PT samples were analyzed multiple times.
D. Finding: PT samples were not documented on benchsheets in the same manner as routine
environmental samples.
Requirement: The analysis of PT samples is designed to evaluate the entire process used to
routinely report environmental analytical results; therefore, PT samples must be analyzed and
the process documented in the same manner as environmental samples. Ref: Proficiency
Testing Requirements, February 20, 2012, Revision 1.2.
E. Finding: The preparation of Proficiency Testing (PT) samples is not documented.
Requirement: PT samples received as ampules must be diluted according to the PT provider's
instructions. The preparation of PT samples must be documented in a traceable log or other
traceable format. The diluted PT sample becomes a routine environmental sample and is added

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#555 Unimin Schoolhouse Quartz Plant
to a routine sample batch for analysis. Ref: Proficiency Testing Requirements, February 20,
2012, Revision 1.2.
F. Finding: The analytical balance is not being checked with three weights on a quarterly basis.
Requirement: The analytical balance must be checked with one class S, or equivalent, standard
weight each day used and at least three standard weights quarterly. The values obtained must be
recorded in a log and initialed by the analyst. Ref: 15A NCAC 2H .0805 (a) (7) (K).
Documentation
Recommendation: As shown below, in the paper trail section, there were a significant number of
transcription errors. It is recommended that a thorough review, preferably a peer review, of all data be
performed on every Discharge Monitoring Report (DMR).
Comment: Decimals were often hard to see on the benchsheets and in some cases were missing. While
no mathematical or transcription errors were found due to this, it may cause the legal defensibility of the
data to be questionable.
G. Finding: Several instances of writing over a number as a means of error correction 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: North Carolina Wastewater/
Groundwater Laboratory Certification Policy.
H. Finding: The date received and date opened is not written on chemical containers.
Requirement: Chemicals must be dated when received and when opened. Reagents must be
dated and initialed when prepared. Ref: 15A NCAC 2H .0805 (a) (7) (L).
Total Suspended Solids — Standard Methods, 191" Edition, 2540 D
1. Finding: A standard is not analyzed quarterly.
Requirement: Excluding Oil and Grease, all residue parameters, leachate extractions, residual
chlorine, and coliform, analyze one known standard in addition to calibration standards each day
samples are analyzed to document accuracy. Analyze one suspended residue, one dissolved
residue, one residual chlorine and one oil and grease standard ug arterly. Ref: 15A NCAC 2H
.0805 (a) (7) (B).
J. Finding: Filters are not weighed to a constant weight after initial washing nor is a dry filter blank
analyzed with each set of samples.
Requirement: If pre -prepared filters are not used, the method requires that filters must be
weighed to a constant weight after washing. In lieu of this process, it is acceptable to analyze a
single daily dry filter blank (i.e., no additional rinsing during the analysis). The acceptance
criterion for the blank is a weight change of less than 4% of the filter's initial weight or 0.5 mg,

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#555 Unimin Schoolhouse Quartz Plant
whichever is less. Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy
based upon Standard Methods, 201h Edition, Method 2540 D. (3) (a).
K. Finding: The samples are not weighed to constant weight, nor is an annual multiple weighing
study, to verify the adequacy of the drying time, performed.
Requirement: Constant weights must be documented. The approved methods require the
following: "Repeat the cycle of drying, cooling, desiccating, and weighing until a constant weight
is obtained or until the weight change is less than 4% of the previous weight or 0.5 mg,
whichever is less." In lieu of this, an annual study documenting the time required to dry
representative samples to a constant weight may be performed. Verify minimum daily drying
time is greater than or equal to the time used for the initial verification study drying cycle. Drying
cycles must be a minimum 1 hour for verification. Ref: North Carolina Wastewater/Groundwater
Laboratory Certification Policy based on Standard Methods 20th Edition, 2540 D. (3) (c), 2540 B.
(3) (b), and 2540 C. (3) (d).
L. Finding: The laboratory is not basing the reporting limit on the minimum weight gain required
by the method.
Requirement: The minimum weight gain allowed by any approved method is 2.5 mg. Choose
sample volume to yield between 2.5 and 200 mg dried residue. This establishes a minimum
reporting value of 2.5 mg/L when 1000 mL of sample is analyzed. If complete filtration takes
more than 10 minutes increase filter diameter or decrease sample volume. In instances where
the weight gain is less than the required 2.5 mg, the value must be reported as less than the
appropriate value based upon the volume used. Ref: North Carolina Wastewater/Groundwater
Laboratory Certification Policy based upon Standard Methods, 20th and 21st Editions, 2540 D.
(3) (b).
Comment: For example, if 500 mL of sample is analyzed and < 2.5 mg of dried residue is
obtained, the value reported would be < 5 mg/L.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing laboratory benchsheets and contract lab reports to Discharge
Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data were
reviewed for June, October and November, 2011. The following errors were noted:
Date
Parameter
Location
Value on Benchsheet
Value on DMR
6/1/11
TSS
Effluent
14.2 mg/L — 166.2 lb/day
3/6 mg/L — 42.1 lb/day
6/20/11
Fluoride
Effluent
7.36 mg/L — 80.8 lb/day
7.86 mg/L — 86.3 lb/day
6/24/11
pH
Effluent
8.6 SU
7.2 SU
6125/11
pH
Effluent
7.4 SU
8.3 SU
6/30/11
Fluoride
Effluent
8.24 mg/L — 82.7 lb/day
8.20 mg/L — 82.3 lb/day
10/2/11
Fluoride
Effluent
9.8 mg/L — 102.1 lb/day
9.4 mg/L — 97.8 lb/day
10/5/11
Turbidity
Effluent
2.3 NTU
2.9 NTU
10/6/11
Turbidity
Effluent
2.8 NTU
2.3 NTU

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#555 Unimin Schoolhouse Quartz Plant
10/7/11
Turbidity
Effluent
3.6 NTU
3.9 NTU
10/11/11
Turbidity
Effluent
4.4 NTU
3.4 NTU
10/14/11
Fluoride
Effluent
8.4 mg/L - 101.3 lb/day
8.0 mg/L - 96.5 lb/day
10/15/11
Fluoride
Effluent
8.7 mg/L - 97.9 lb/day
8.8 mg/L - 98.9 lb/day
10/16/11
Fluoride
Effluent
8.4 mg/L - 89.7 lb/day
8.5 mg/L - 90.3 lb/day
10/17/11
Fluoride
Effluent
8.6 mg/L - 89.5 lb/day
8.8 mg/L - 91.3 lb/day
10/18/11
Turbidity
Effluent
2.3 NTU
2.8 NTU
10/19/11
Turbidity
Effluent
2.9 NTU
2.0 NTU
10/19/11
Fluoride
Effluent
9.8 mg/L - 93.4 lb/day
9.0 mg/L - 75.1 lb/day
10/20/11
Turbidity
Effluent
2.6 NTU
9.0 NTU
10/20/11
Fluoride
Effluent
9.3 mg/L - 99.4 lb/day
9.9 mg/L - 105.9 lb/day
10/21/11
Fluoride
Effluent
9.9 mg/L - 69.8 lb/day
9.2 mg/L - 66.5 lb/day
10/25/11
Turbidity
Effluent
4.8 NTU
4.2 NTU
10/25/11
Fluoride
Effluent
8.9 mg/L - 98.5 lb/day
8.6 mg/L - 84.2 lb/day
10/26/11
Turbidity
Effluent
2.0 NTU
2.8 NTU
10/28/11
Turbidity
Effluent
2.2 NTU
2.8 NTU
10/28/11
Fluoride
Effluent
8.7 mg/L - 105.3 lb/day
8.6 mg/L - 103.8 lb/day
10/30/11
Fluoride
Effluent
8.6 mg/L - 90.2 lb/day
8.0 mg/L - 83.9 lb/day
11 /9/11
pH
Effluent
8.6 SU
8.0 SU
11/16/11
Turbidity
Effluent
8.7 NTU
3.7 NTU
11/24/11
Turbidity
Effluent
2.8 NTU
3.8 NTU
11/27/11
Fluoride
Effluent
9.4 mg/L - 104 lb/day
9.1 mg/L - 100.5 lb/day
Due to the unusual number of transcription errors, the Asheville Regional Office has requested
amended DMRs for June, October, and November, 2011.
V. CONCLUSIONS:
Correcting the above -cited findings and implementing the recommendations 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: April 18, 2012
Report reviewed by: Todd Crawford Date: April 19, 2012