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HomeMy WebLinkAbout#5064_2023_0608_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 July 12, 2023 5064 Mr. Joseph Heath Slade Duke Energy Progress - Mayo Electric Generating Plant 10660 Boston Road Roxboro, NC 27574- Subject: North Carolina Wastewater/Groundwater Laboratory Certification Branch (NC WW/GW LCB) Maintenance Inspection Dear Mr. Slade: Enclosed is a report for the inspection performed on June 8, 2023 by Tonja Springer. 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: Todd Crawford, Tonja Springer, #5064 On-Site Inspection Report LABORATORY NAME: Duke Energy Progress - Mayo Electric Generating Plant WATER QUALITY PERMIT #: NC0038377 STORMWATER PERMIT #: NCS000580 NC GENERAL PERMIT #: CERTIFICATE #: NCG120101 5064 DATE OF INSPECTION: June 8, 2023 TYPE OF INSPECTION: Field Industrial Maintenance AUDITOR(S): Tonja Springer LOCAL PERSON(S) CONTACTED: Joseph Heath Slade, Cale Walker and Leanne Wilson 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 facility is neat and well organized and has all the equipment necessary to perform the analyses. The analysts were forthcoming and responded well to suggestions from the auditor. All required Proficiency Testing (PT) Samples have been analyzed for the 2023 PT Calendar Year and the graded results were 100% acceptable. Any time changes are made to laboratory procedures, Quality Assurance (QA) and/or Standard Operating Procedure (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 SOPs, based on the Findings, Comments and Recommendations within this report must be submitted to this office with the response to this report. The laboratory is reminded that SOPs are required to be reviewed at least every two years and 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”. Page 2 # 5064 Duke Energy Progress - Mayo Electric Generating Plant Contracted analyses are performed by Pace Analytical Services LLC - Huntersville NC (Certification # 12), Duke Power Company LLC d/b/a Duke Energy Carolinas LLC (Certification # 248) and Pace Analytical Services LLC - West Columbia (Certification # 329). Approved Procedure documents for the analysis of the facility’s currently certified Field Parameters were provided at the time of the inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Reporting Comment: The laboratory was not reporting results of all tests on the characteristics of the effluent when duplicate sample analyses are performed. The first result is reported on the Discharge Monitoring Report (DMR). North Carolina Administrative Code, 15A NCAC 02B .0506 (b) (3) (J) states: 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. Acceptable corrective action (i.e., verbal agreement to immediately cease analyzing pH samples in duplicate, followed up in writing via email on June 29, 2023) was performed by the laboratory and approved by the auditor during the inspection. No further response is necessary for this Corrected Finding. Documentation A. Finding: The field notebook is lacking required documentation: the method or Standard Operating Procedure reference; the laboratory identification; the instrument identification; the sample collector; the signature or initials of the analyst; the time of sample analyses, sample identification and the proper 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, the laboratory identification, the instrument identification, the sample collector, the signature or initials of the analyst, the time of sample analyses, sample identification and the proper units of measure. Ref: 15A NCAC 02H .0805 (g) (2) (A) (B), (C), (D), (E), (H), (I) and (L). Comment: This finding applies to Temperature analyzed at Outfall 002A. Comment: The sample time and results are documented in the notebook, but they are not labeled as such. The results are then added to a spreadsheet on the computer. The spreadsheet is printed out at the end of the month and results transcribed on the DMR. B. Finding: The laboratory does not document QC assessments on the laboratory benchsheet. Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data shall be traceable to the associated sample analyses and shall consist of: the quality control assessments. Each item shall be recorded each time samples are analyzed. Ref: 15A NCAC 02H .0805 (g) (2) (O). Comment: This Finding applies to pH. The pH check buffer acceptance criterion is documented on the benchsheet. There is no documentation showing that the analyst assesses the values obtained against the acceptance range. A check box indicating that the acceptance criterion has been met would satisfy this requirement. No data were observed where the QC results were outside the acceptance criterion. Page 3 # 5064 Duke Energy Progress - Mayo Electric Generating Plant Proficiency Testing C. Finding: The laboratory is not documenting PT Sample analyses in the same manner as routine Compliance Samples. Requirement: All PT Sample analyses must be recorded in the same daily analysis records (e.g., benchsheets) as for any Compliance Sample. This serves as the permanent laboratory record. Ref: Proficiency Testing Requirements, January 1, 2023, Revision 6, Section 3.6. Comment: The laboratory is currently documenting the PT Sample results on a separate sheet of paper that is attached to the pH calibration along with the PT vendor reporting form. D. Finding: PT Samples are not 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, January 1, 2023, Revision 6, Section 3.6. pH – Standard Methods, 4500 H+ B-2011 (Aqueous) E. 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-2011. (6). Comment: Per PT Vendor instructions, the PT Sample results should be reported to two decimal places, which is an exception to the requirement for Compliance Samples. Recommendation: The laboratory currently reports pH sample results to two decimal places. It is recommended that the laboratory continue to measure and document sample results on the benchsheet to two decimal places, and to round to the nearest 0.1 S.U. when reporting results on the DMR. Temperature – Standard Methods, 2550 B-2010 (Aqueous) Comment: Temperature is being reported to 0.1°C on the Discharge Monitoring Report (DMR). Recommendation: Unless greater precision is required by the permit or data receiving agency, it is recommended that all temperatures reported for compliance monitoring, be reported in whole numbers as recommended by the DWR’s Precision in Discharge Monitoring Reports document. IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks, etc.) and contract laboratory reports to DMRs submitted to the North Carolina Division of Water Resources. Data were reviewed for Duke Energy - Mayo Steam Electric Generating Plant (NPDES permit #NC0038377) for March 2023. No transcription errors were observed. The facility appears to be doing a good job of accurately transcribing data. Page 4 # 5064 Duke Energy Progress - Mayo Electric Generating Plant V. CONCLUSIONS: Correcting the above-cited Findings and implementing the Recommendation(s) 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: June 29, 2023 Report reviewed by: Michael Cumbus Date: July 5, 2023 Certificate Number:5064 Effective Date:1/1/2023 Expiration Date:12/31/2023 Lab Name:Duke Energy Progress - Mayo Electric Generating Plant Address:10660 Boston Road Roxboro, NC 27574- North Carolina Wastewater/Groundwater Laboratory Certification Certified Parameters Listing Date of Last Amendment:7/24/2018 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.