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HomeMy WebLinkAbout#5151_2019_0821_MC_FINALLaboratory Cert. #: 5151 Laboratory Name: Duke Power Company LLC d/b/a Duke Energy Carolinas LLC - Buck Inspection Type: Field Municipal Maintenance Inspector Name(s): Michael Cumbus and Beth Swanson Inspection Date: August 21, 2019 Date Forwarded for Initial Review: September 6, 2019 Initial Review by: Tom Halvosa Date Initial Review Completed: September 18, 2019 Cover Letter to use: ❑ Insp. Initial ® Insp. Reg ❑Insp. No Finding ❑Insp. CP ❑Corrected ❑Insp. Reg. Delay Unit Supervisor/Chemist III: Beth Swanson Date Received: September 18, 2019 Date Forwarded to Admin.: September 20, 2019 Date Mailed: September 20, 2019 Special Mailing Instructions: Michael to email a copy to the Mooresville Regional Office ROY COOPER ICHAEL S, RED A iN Sa 4 ri'kl(y LI DA CUREPPER nferiml F')sr(,�,ficjf EnvironmentW Quality September 20, 2019 5151 Mr. Girish C. Sharma Duke Power Company LLC d/b/a Duke Energy Carolinas LLC - Buck 13339 Hagers Ferry Road Bldg. 7405 Mail Code: MG03A2 Huntersville, NC 28078-7929 Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Sharma: 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 (919) 733-3908 Ext. 259. Sincerely, /11 Beth Swanson Technical Assistance & Compliance Specialist Division of Water Resources Attachment cc: Michael Cumbus, Dana Satterwhite, Mooresville Regional Office North Carolina Department of Environmental Quality I Division of Water Resources 1623 Mail Service Center I Raleigh, North Carolina 27699-1623 Phone 919.733.3908/Fax 91.9.733.6241, LABORATORY NAME: Duke Power Company LLC d/b/a Duke Energy Carolinas LLC - Buck ADDRESS: 1385 Dukeville Rd, Salisbury, NC 28146 CERTIFICATE #: 5151 DATE OF INSPECTION: August 21, 2019 TYPE OF INSPECTION Field Industrial Maintenance AUDITOR(S): Michael Cumbus and Beth Swanson LOCAL PERSON(S) CONTACTED: Dale Wooten, Girish C. Sharma 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. II. GENERAL COMMENTS: 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. The laboratory has been proactive in keeping up with updates and changes required by this Program, particularly in the area of consumable traceability. All required Proficiency Testing (PT) Samples have been analyzed for the 2019 PT Calendar Year and the graded results were 100% acceptable. Contracted analyses are performed by Shealy Environmental Services Inc. (Certification #329), Pace Analytical Services LLC (Certification #12) and Duke Power Company LLC d/b/a Duke Energy Carolinas LLC (Certification #248). Approved Procedure documents for the analysis of the facility's currently certified Field Parameters were provided at the time of the inspection. Page 2 #111 Lab Name Documentation Comment: The laboratory informed the auditors during the paper trail investigation that when contract data is received with a qualifier, the letter of the qualifier was entered into the data cell of the Discharge Monitoring Report (DMR). North Carolina Administrative Code, 15A NCAC 2H .0805 (e) (5) states: Reported data associated with quality control failures, improper sample collection, holding time exceedances, or improper preservation shall be qualified as such. Notation must be made in the comment section of the DMR. This would include any letter used as a data qualifier as well as a brief description of the quality control exceedance. A. Finding: The laboratory benchsheet is lacking pertinent data: Sample identification. 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). Requirement: The following must be documented in indelible ink whenever sample analysis is performed: sample site (ID or location). Ref: NC WW/GW LC Approved Procedure for the Analysis of pH and NC WW/GW LC Approved Procedure for the Analysis of Temperature. Comment: The laboratory benchsheet utilized site descriptors that differed from the permitted site ID. The downstream site noted as "002" is listed on the DMR as "007". There is also a permitted outfall site "002", which can lead to further confusion when site descriptors do not match the permitted site ID. D. Finding: The laboratory benchsheet is lacking pertinent data: Method reference 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 method or Standard Operating Procedure and the proper units of measure. Ref: 15A NCAC 2H .0805 (g) (2) (A) and (L). Requirement: The following must be documented in indelible ink whenever sample analysis is performed: Method reference and units of measure. Ref: NC WW/GW LC Approved Procedure for the Analysis of pH and NC WW/GW LC Approved Procedure for the Analysis of Temperature. Comment: pH units of measure (S.U.) were missing for the month of August. C. Finding: The laboratory benchsheet is lacking pertinent data: permit number. Requirement: The following must be documented in indelible ink whenever sample analysis is performed: Facility name and permit number. Ref: NC WW/GW LC Approved Procedure for the Analysis of pH and NC WW/GW LC Approved Procedure for the Analysis of Temperature. Page 3 #111 Lab Name Comment: The calibration of the pH meter was documented on the PT data sheet, not in the instrument calibration log used for compliance samples. Recommendation: It is recommended that the laboratory record the calibration of the pH meter for PT Sample analyses in the calibration log used for routine compliance samples, and that the time of analysis of the PT Samples be documented to ensure that analysis did not occur prior to calibration. D. 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 Sample analysis is conducted. Ref: Proficiency Testing Requirements, October 29, 2018, Revision 3. E. Finding: The laboratory does not report results of all tests on the characteristics of the effluent when duplicate sample analyses are performed. 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 213.0506 (b) (3) (J). Comment: If the average value of multiple sample measurements is not reported, the following convention must be followed when deciding which value to report in the daily cell: Any value in violation of permit limits must be reported in the daily cell. If multiple samples yielded noncompliant results, the most extreme noncompliant value must be reported in the daily cell. If all values taken during the day were compliant with the permit limits, the value closest to the bounds of the limit range (high or low) must be reported in the daily cell. The other value not reported in the daily cell must be reported in the comment section. Comment: The laboratory received values of 19.8 NTU and 20.5 NTU for turbidity samples collected on July 2, 2019 from site 007, but only 19.8 NTU was entered into the DMR. Temperature — Standard Methods, 2550 B-2011 (Aqueous) F. Finding: The laboratory is not verifying the compliance temperature -measuring device every 12 months. Requirement: All compliance temperature -measuring devices without a valid NIST certificate must be checked initially and every 12 months against an NIST traceable temperature -measuring device and the process documented. Documentation must include Page 4 #111 Lab Name the serial number of the device being checked. The serial number, stated accuracy and expiration date of the NIST traceable temperature -measuring device used in the comparison must also be documented. Verification data must be kept on file and be available for inspection for 5 years. (NOTE: Vendors or other Certified laboratories may provide assistance in meeting this requirement. When a vendor or other Certified laboratory provides this assistance, they must provide a copy of their NIST Certificate or the serial number, accuracy and calibration expiration date.) Ref: NC WW/GW LC Approved Procedure for the Analysis of Temperature. Comment: The laboratory last verified the compliance temperature -measuring device in November 2018. Previously, the device had been verified in September 2017. -. z M441NTNUOUITIF The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks, etc.) and contract lab reports to DMRs submitted to the North Carolina Division of Water Resources. Data were reviewed for Duke Power Company LLC d/b/a Duke Energy Carolinas LLC — Buck (NPDES permit # NC0004774) for May and July, 2019. The following errors were noted: Value on Benchsheet Date Parameter Location Value on DMR *Contract Lab Data 7/2/2019 Turbidity 007 * 20.5 N.T.U. Not Reported To avoid questions of legality, it is recommended that you contact the appropriate Regional Office for guidance as to whether an amended DMR will be required for the July 2, 2019 data. A copy of this report will be made available to the Regional Office. V. CONCLUSIONS: 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: September 6, 2019 Report reviewed by: Tom Halvosa Date: September 18, 2019 North Carolina Wastewater/Groundwater Laboratory Certification Certified Parameters Listing Lab Name: Duke Power Company LLC d/b/a Duke Energy Carolinas LLC - Buck Address: 1385 Dukeville Rd Salisbury, NC 28146-8613 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) Certificate Number: 5151 Effective Date: 1/1/2019 Expiration Date: 12/31/2019 Dale of Last Amendment: This certification requires maintance of an acceplable 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.