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HomeMy WebLinkAbout#5193_2016_0127_BS_FINALINSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: Laboratory Name: Inspection Type: Inspector Name(s): Inspection Date: Date Report Completed: Date Forwarded to Reviewer: Reviewed by: Date Review Completed: Cover Letter to use: Unit Supervisor/Chemist III: Date Received: Date Forwarded to Linda: Date Mailed: 5193 Duke Power Company LLC d/b/a Duke Energy Carolinas, LLC - Sci Support Field Maintenance Beth Swanson, Gary Francies 1 /27/16 2/5/2016 2/8/2016 Nick Jones 2/11/2016 ❑ Insp. Initial ❑ Insp. No Finding ® Corrected Gary Francies 2/11/2016 2/15/2016 2/16/2016 ❑ Insp. Reg. ❑ Insp. CP ❑ Insp. Reg. Delay Water Resources ENV IRONMENTAf_ QUALI' Y February 16, 2016 PAT MCCRORY ,emr,r DONALD R. VAN DER VAART 5193 Mr. Matt McKinney Duke Power Company LLC d/b/a Duke Energy Carolinas, LLC- Sci Support 13339 Hagers Ferry Rd. Bldg. 7405 Huntersville NC, 28078 )"W'! S. JAY ZIMMERMAN rJin'Clor SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. McKinney: Enclosed is a report for the inspection performed on January 27, 2016 by Beth Swanson and Gary Francies. Since the Finding(s) cited during the inspection were all corrected prior to the completion of the enclosed report, a response is not required. The staff is commended for taking the initiative in correcting the Findings in such a timely manner. 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. Attachment cc: Beth Swanson Master File Sincerely, Gary Francies, Technical Assistance/Compliance Specialist Division of Water Resources Water Sciences 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 Phone: 919-733-39081 FAX: 919-733-6241 Internet: hitp:H ortal.r cdenr.org/web/wq/€ablcert LABORATORY NAME: Duke Power Company LLC d/b/a Duke Energy Carolinas, LLC- Sci Support ADDRESS: 13339 Hagers Ferry Rd. Bldg. 7405 Huntersville NC, 28078 CERTIFICATE #: 5193 DATE OF INSPECTION: TYPE OF INSPECTION: AUDITOR(S): LOCAL PERSON(S) CONTACTED: INTRODUCTION: January 27, 2016 Field Maintenance Beth Swanson and Gary Francies Matt McKinney, Josh Quinn and Glenn Long 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. GENERAL COMMENTS: The facility has all the equipment necessary to perform the analyses. Staff were forthcoming and helpful in answering our questions. They were eager to implement corrective actions and recommendations. Proficiency Testing (PT) samples were analyzed for all certified parameters for the 2015 proficiency testing calendar year and the graded results were 100% acceptable. Contracted analyses are performed by Duke Power Company LLC d/b/a Duke Energy Carolinas, LLC (Certification #248). Current Quality Assurance Policies for Field Laboratories and Approved Procedures for the analysis of the facility's currently certified parameters were provided at the time of the inspection. The facility is only analyzing Dissolved Oxygen samples with LDO technology (i.e., ASTM D 888-09 C) so the membrane method (i.e., Standard Methods, 4500 O G-2001) was removed from their Certified Parameters Listing, effective February 5, 2016. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation Comment: Improper error correction was noted during the inspection. Error corrections were not dated. NC WW/GW LC Policy states: 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. Page 2 #5193 - Duke Power Company LLC d/b/a Duke Energy Carolinas, LLC - Sci Support Pencil entries are not acceptable. Notification of acceptable corrective action (i.e., a statement that the requirement was added to the benchsheet and the practice was implemented on January 29, 2016) was received by email on February 3, 2016. No further response is necessary for this Finding. Comment: The preparation of Proficiency Testing (PT) samples is not documented. The Proficiency Testing Requirements, February 20, 2012, Revision 1.2 document states: 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 to a routine sample batch for analysis. Notification of acceptable corrective action (i.e., a statement that beginning with the next PT samples analyzed, the PT vendor's instructions will be signed, dated, and retained) was received by email on February 3, 2016. No further response is necessary for this Finding. Comment: The "hydro NPDES" benchsheet was lacking pH units (i.e., S.U.). North Carolina Administrative Code 15A NCAC 02H .0805 (g) (1) states: 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 bench sheets must provide a space for the signature or initials of the analyst, and proper units of measure for all analyses. Notification of acceptable corrective action (i.e., pH units were added to the hydro NPDES benchsheet currently in use) was received by email on February 3, 2016. No further response is necessary for this Finding. Comment: The laboratory needed to increase the documentation of purchased materials and reagents, as well as documentation of standards and reagents prepared in the laboratory. Traceability information was being documented on the reagent bottles, but the linkage is lost once the bottles are discarded. The Quality Assurance Policies for Field Laboratories document 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 A system (e.g., traceable identifiers) must be in place that links standard/reagent preparation information 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 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. Notification of acceptable corrective action (i.e., a receipt log with the required information was created and implemented on January 29, 2016) was received by email on February 3, 2016. No further response is necessary for this Finding. pH — Standard Methods, 4500 H+ B-2000 Comment: Calibration of the pH meter was not consistently carried out. Before each analysis, the analyst would read three buffers. If the pH reading for a buffer was the same as the known value, then that buffer was not used to calibrate (i.e., the "calibrate" button would not be pushed). So, there were days when the meter was not calibrated with at least two buffers. The Approved Procedure for the Analysis of pH document states: For routine work, use a pH meter accurate and reproducible to 0.1 pH unit with a range of 0 to 14, equipped with a temperature compensation device. Follow all manufacturers' recommendations for the calibration of the meter each analysis day. The meter must be calibrated with at least two buffers. In addition to the calibration standards, the meter must be verified with a third calibration standard. Notification of acceptable corrective action (i.e., a statement that the requirement was added to the benchsheet and the practice was implemented on January 29, 2016) was received by email on February 3, 2016. No further response is necessary for this Finding. Page 3 #5193 - Duke Power Company LLC d/b/a Duke Energy Carolinas, LLC - Sci Support Dissolved OXygen — ASTM D 888-9 C (LDO) Recommendation: It is recommended that the laboratory standardize the titrant monthly due to the instability of sodium thiosulfate. The laboratory currently verifies the LDO meter calibration using Winkler titration with sodium thiosulfate titrant. The laboratory purchases prepared 0.025M sodium thiosulfate. Currently, no standardization is performed on the titrant. The Winkler titration method found in Standard Methods, 4500 O C-2001 states that the prepared sodium thiosulfate is standardized with each use, but since this is a purchased reagent, we feel the statement in Standard Methods, 2020 B-2010. (2) (b) that reagents be standardized once a month is more applicable. The laboratory was originally told that this would be a requirement based on NC WW/GW LC policy, however this policy was revoked after the 40 CFR 2012 Method Update covered all other instances of titrant standardization. Conductivity — Standard Methods, 2510 B-1997 Comment: The laboratory did not consistently use a standard at 250C for the annual Automatic Temperature Compensation verification. In 2015, the standard was 25.35°C and in 2016 it was 26.8°C. The temperature may not vary by more than ± 0.5°C. The Approved Procedure for the Analysis of Conductivity states: The Automatic Temperature Compensator (ATC) must be verified annually (i.e., 12 months) at two temperatures by analvzina a standard or sample at 250C (the temperature that conductivity values are compensated to) and a temperature(s) that brackets the temperature ranges of the environmental samples routinely analyzed. Notification of acceptable corrective action (i.e., a statement that the next ATC verification will include a standard at 25°C ± 0.5°C) was received by email on February 3, 2016. No further response is necessary for this Finding. Chlorine, Total Residual — Standard Methods, 4500 Cl G-2000 Comment: The laboratory is currently constructing their own curve annually. It was noted at the time of inspection that the laboratory may instead choose to verify the internal curve annually. Currently, only PT samples are analyzed for Total Residual Chlorine (TRC), but if the laboratory decides to continue constructing their own curve and additional TRC samples are analyzed, each analyst who analyzes samples must construct and use their own curve. IV. PAPER TRAIL INVESTIGATION: No paper trail was performed. There are no client reports or Discharge Monitoring Reports to compare. V. CONCLUSIONS: All Findings noted during the inspection were adequately addressed prior to the completion of this report. The inspectors would like to thank the staff for its assistance during the inspection and data review process. No response is required. Report prepared by: Beth Swanson Date: February 5, 2016 Report reviewed by: Nick Jones Date: February 11, 2016