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Home My WebLink About#5101_2022_0913_TS_FINAL NC Department of Environmental Quality | Division of Water Resources | Laboratory Certification Branch 4405 Reedy Creek Road | 1623 Mail Service Center | Raleigh, North Carolina 27699-1623 919-733-3908 November 4, 2022 5101 Ms. Leanne Wilson Duke Energy Carolinas - Cape Fear Plant 500 CP&L Road Moncure, NC 27559- Subject: North Carolina Wastewater/Groundwater Laboratory Certification Branch (NC WW/GW LCB) Maintenance Inspection Dear Ms. Wilson: Enclosed is a report for the inspection performed on September 13, 2022 by Tonja Springer. 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, 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 02H .0800. A copy of the laboratory’s Certified Parameter List at the time of the audit is attached. This list will not 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 have questions or need additional information, please contact me at (919) 733- 3908 Ext. 259. Sincerely, Beth Swanson Technical Assistance & Compliance Specialist Division of Water Resources Attachment cc: Tonja Springer, Todd Crawford, #5101 On-Site Inspection Report LABORATORY NAME: Duke Energy Carolinas - Cape Fear Plant NPDES PERMIT #: NC0003433 ADDRESS: 500 CP&L Road Moncure, NC 27559 CERTIFICATE #: 5101 DATE OF INSPECTION: September 13, 2022 TYPE OF INSPECTION: Field Industrial Maintenance AUDITOR(S): Tonja Springer LOCAL PERSON(S) CONTACTED: Jonathan Stamas I. INTRODUCTION: This laboratory was inspected by a representative of the North Carolina Wastewater/Groundwater Laboratory Certification Branch (NC WW/GW LCB) to verify its compliance with the requirements of 15A NCAC 02H .0800 for the analysis of compliance monitoring samples. II. GENERAL COMMENTS: The laboratory submitted requested documentation electronically September 8, 2022 and September 12, 2022. The inspection was performed via WebEx on September 13, 2022. All required Proficiency Testing (PT) Samples have been analyzed for 2022 PT Calendar year and graded results were 100% acceptable. The laboratory is reminded that any time changes are made to laboratory procedures, QA/SOP document(s) must be updated and relevant staff retrained. Staff must acknowledge that they have read and understand the changes as part of the documented training program. The same requirements apply when changes are made in response to Findings, Recommendations or Comments listed in this report, to ensure the methods are being performed as stated, references to methods are accurate, and the QA and/or SOP document(s) is in agreement with each approved practice, test, analysis, measurement, monitoring procedure or regulatory requirement being used in the laboratory. In some instances, the laboratory may need to create an SOP to document how new functions or policies will be implemented. Revisions to the SOP, based on the Findings, Comments and Recommendations within this report must be submitted to this office by January 31, 2023. The laboratory is also reminded that SOPs are intended to describe procedures exactly as they are to be performed. Use of the word “should” is not appropriate when describing requirements (e.g., Quality Control (QC) frequency, acceptance criteria, etc.). Evaluate all SOPs for the proper use of the word “should”. Contracted analyses are performed by Pace Analytical Services LLC - Asheville NC (Certification #40). Page 2 #5101 – Duke Energy Carolinas – Cape Fear Plant The Approved Procedure document for the analysis of the facility’s currently certified Field Parameter was provided at the time of the inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Comment: No compliance samples are being analyzed for pH and Temperature. The Temperature monitoring requirement was removed from the permit when it was renewed in 2020. Temperature was dropped from the Certified Parameter Listing (CPL) on October 25, 2022. The laboratory has sent a written request to make the laboratory inactive after December 31, 2022. Only pH Proficiency Testing (PT) data was available for review. Documentation A. Finding: The units of measure for pH (i.e., Standard Units or S.U.) are not documented on the benchsheet. Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data shall be traceable to the associated sample analyses and shall consist of: the proper units of measure. Each item shall be recorded each time samples are analyzed. Analyses shall conform to methodologies found in Subparagraph (a) (1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (2) (L). Comment: The pH PT Sample result is documented on the bottom of the benchsheet and does not include units. IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing the laboratory benchsheet and the PT vendor reporting form. No transcription errors were observed. The facility appears to be doing a good job of accurately transcribing data. V. CONCLUSIONS: Correcting the above-cited Finding 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: Tonja Springer Date: September 21, 2022 Report reviewed by: Jill Puff Date: October 25, 2022 Certificate Number:5101 Effective Date:1/1/2022 Expiration Date:12/31/2022 Lab Name:Duke Energy Carolinas - Cape Fear Plant Address:500 CP&L Road Moncure, NC 27559- North Carolina Wastewater/Groundwater Laboratory Certification Certified Parameters Listing Date of Last Amendment: The above named laboratory, having duly met the requirements of 15A NCAC 2H.0800, is hereby certified for the measurement of the parameters listed below. CERTIFIED PARAMETERS INORGANIC pH SM 4500 H+B-2011 (Aqueous) TEMPERATURE SM 2550 B-2010 (Aqueous) This certification requires maintance of an acceptable quality assurance program, use of approved methodology, and satisfactory performance on evaluation samples. Laboratories are subject to civil penalties and/or decertification for infractions as set forth in 15A NCAC 2H.0807.