#5155_2017_0915_BS_FINAL

INSPECTION REPORT ROUTING SHEET

To be attached to all inspection reports in-house only.

Laboratory Cert. #: 5155
Laboratory Name: Duke Power Company LLC d/b/a Duke Energy Carolinas LLC – Marshall
Inspection Type: Field Industrial Maintenance
Inspector Name(s): Beth Swanson
Inspection Date: September 15, 2017
Date Forwarded for Initial
Review: September 27, 2017
Initial Review by: Jason Smith
Date Initial Review
Completed: September 29, 2017
Cover Letter to use:
Insp. Initial
Insp. No Finding
Corrected

Insp. Reg
Insp. CP
Insp. Reg. Delay
Unit Supervisor/Chemist III: Dana Satterwhite
Date Received: September 29, 2017
Date Forwarded to Admin.: October 25, 2017
Date Mailed: October 25, 2017
Special Mailing Instructions:

On-Site Inspection Report

LABORATORY NAME: Duke Power Company LLC d/b/a Duke Energy Carolinas LLC –
Marshall

NPDES PERMIT #: NC0004987

ADDRESS: 8320 NC Hwy 150 E.
Terrell, NC 28682

CERTIFICATE #: 5155

DATE OF INSPECTION: September 15, 2017

TYPE OF INSPECTION: Field Industrial Maintenance

AUDITOR(S): Beth Swanson

LOCAL PERSON(S) CONTACTED: Paul Sabol

I. INTRODUCTION:

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.

II. GENERAL COMMENTS:

The facility is clean and spacious. The analyst was receptive to all comments and
recommendations made during the inspection.

All required Proficiency Testing (PT) Samples have been analyzed for the 2017 PT Calendar Year
and the graded results were 100% acceptable.

Requirements that reference 15A NCAC 2H .0805 (g) (1), stating “Data pertinent to each analysis
must be maintained for five years. Certified Data must consist of date collected, time collected,
sample site, sample collector, and sample analysis time. The field benchsheets must provide a
space for the signature or initials of the analyst and proper units of measure for all analyses”, are
intended to be a requirement to document all pertinent information for historical reconstruction of
data. 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 Duke Power Company LLC d/b/a Duke Energy Carolinas
LLC (Certification # 248), Prism Laboratories Inc. (#402) and Shealy Environmental Services Inc.
(#329).

III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:

Proficiency Testing

Comment: The laboratory is reminded that the Proficiency Testing Requirements document
states: 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
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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. The laboratory
personnel changed less than one year ago, so this will be a requirement going forward.

A. Finding: The laboratory is not documenting PT Sample analyses in the same manner as
routine Compliance Samples.

Requirement: As specified in 15 NCAC 2H .0800, in order to meet the minimum standards
for Certification, laboratories must use acceptable analytical methods. The acceptable
methods are those defined or referenced in the current State and federal regulations for the
environmental matrix being tested. All samples, (including PT Samples) that are, or that
may, be used for Certification purposes, must be analyzed using approved methods only.
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. Laboratories must
document any exceptions. 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, May 31, 2017, Revision 2.0.

Documentation

B. Finding: Error corrections are not always properly performed.

Requirements: 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: Quality Assurance Policies for Field Laboratories.

Comment: Instances of write-overs and not initialing and dating corrections were found.

C. Finding: The laboratory needs to increase the traceability documentation of purchased
materials.

Requirement: 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. This information as well as the vendor and/or
manufacturer, lot number, and expiration date must be retained for chemicals, reagents,
standards and consumables used for a period of five years. Consumable materials such as
pH buffers and lots of pre-made standards are included in this requirement. Ref: Quality
Assurance Policies for Field Laboratories.

Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A
NCAC 2H .0805 (g) (1).

Comment: The reagent log does not include the date received.

pH – Standard Methods, 4500 H+ B- 2000 (Aqueous)

D. Finding: The laboratory benchsheet was lacking pertinent data: instrument identification.

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Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: instrument identification. Ref: NC WW/GW LC Approved Procedure
for the Analysis of pH.

Comment: The separate pH calibration benchsheet does not include the instrument
identification.

E. Finding: The laboratory benchsheet was lacking pertinent data: units of measure.

Requirement: Data pertinent to each analysis must be maintained for five years. Certified
data must consist of date collected, time collected, samples site, sample collector, and
sample analysis time. The field bench sheets must provide a space for the signature of the
analyst, and proper units of measure for all analyses. Ref: 15A NCAC 2H .0805 (g) (1).

Comment: The calibration benchsheet includes units of measure, but the results
benchsheet does not.

F. 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 pH
unit. Ref: Standard Methods, 4500 H+ B-2000. (6).

Temperature – Standard Methods, 2550 B- 2000 (Aqueous)

G. Finding: The acceptance range for temperature sensor checks exceeds ± 0.5 °C (i.e., 0.9
°F).

Requirement: All thermometers and temperature measuring devices used for compliance
monitoring must be checked every 12 months against a NIST traceable temperature
measuring device and the process documented. To check a thermometer or temperature
sensor of a meter, read the temperature of the thermometer/meter against a NIST
traceable temperature measuring device and record the two temperatures. The verification
must be performed in the approximate range of the sample temperatures measured. The
thermometer/meter readings must be less than or equal to 0.5ºC from the NIST traceable
temperature measuring device reading. If it is not, the thermometer/meter may not be used
for compliance monitoring. The calibration verification documentation must include the
serial number of the thermometer/meter being checked and the NIST traceable
temperature measuring device that was used in the comparison. Document the verification
data and keep on file. (NOTE: Other Certified laboratories may provide assistance in
meeting this requirement). Ref: NC WW/GW LC Approved Procedure for the Analysis of
Temperature.

Comment: The facility has a network of resistance temperature detector units, each of
which has multiple sensors that are continuously monitoring the temperature of the
receiving water. All this data is compiled and averaged using a program designed by the
facility and one number is reported each day. The units are checked against the certified
thermometer every 12 months and correction curves for each unit are generated. The
curves are used in the program mentioned previously to obtain a daily temperature result. If
the readings of any sensors do not agree with the certified thermometer within ±3 °F, that
sensor undergoes maintenance or is taken out of service.

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IV. PAPER TRAIL INVESTIGATION:

The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) and contract lab reports to eDMRs submitted to the North Carolina Division of Water
Resources. Data were reviewed for Duke Power Company LLC d/b/a Duke Energy Carolinas
LLC – Marshall (NPDES permit # NC0004987) for January, April and June 2017. No
transcription errors were observed. The facility appears to be doing a good job of accurately
transcribing data.

V. CONCLUSIONS:

Correcting the above-cited Findings 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: Beth Swanson Date: September 27, 2017
Report reviewed by: Jason Smith Date: September 29, 2017