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Home My WebLink About#5052_2012 INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5052 Laboratory Name: Progress Energy Carolinas – Brunswick Steam Electric Plant Inspection Type: Field Maintenance Inspector Name(s): Todd Crawford Inspection Date: May 22, 2012 Date Report Completed: June 1, 2012 Date Forwarded to Reviewer: June 1, 2012 Reviewed by: Jeff Adams Date Review Completed: June 4, 2012 Cover Letter to use: Insp. Initial Insp. Reg. Insp. No Finding Insp. CP _X_ Corrected Unit Supervisor: Dana Satterwhite Date Received: June 5, 2012 Date Forwarded to Linda: June 7, 2012 Date Mailed: June 7, 2012 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Progress Energy Carolinas – Brunswick Steam Electric Plant NPDES Permit #: NC0007064 ADDRESS: P.O. Box 10429 Southport, NC 28461 CERTIFICATE #: 5052 DATE OF INSPECTION: May 22, 2012 TYPE OF INSPECTION: Field Maintenance AUDITOR(S): Todd Crawford LOCAL PERSON(S) CONTACTED: Marty McGowan, Chuck Nelson and Charlie Wilson I. INTRODUCTION: This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for the analysis of environmental samples. II. GENERAL COMMENTS: The laboratory was clean and well organized. The facility has all the equipment necessary to perform the analyses. The system for traceability of consumables and standards was in place but cumbersome to navigate. Proficiency Testing (PT) samples have been analyzed for all certified parameters for the 2011 proficiency testing calendar year and the graded results were 100% acceptable. Please be reminded that acceptable PT results must be received in our office before September 30, 2012 in order to satisfy the 2012 PT requirements. Contracted analyses are performed by Environmental Chemists, Inc. (Certification #94). The laboratory is reminded that any time changes are made to laboratory operations; the laboratory must update the Quality Assurance (QA)/Standard Operating Procedures (SOP) document(s). Any changes made in response to the Findings, Recommendations or Comments listed in this report must be incorporated to insure the method is being performed as stated, references to methods are accurate, and the QA and/or SOP document(s) is in agreement with approved practice and regulatory requirements. In some instances, the laboratory may need to create a SOP to document how new functions or policy will be implemented. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation 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 Page 2 #5052 Progress Energy Carolinas – Brunswick Steam Electric Plant routine environmental sample and is added to a routine sample batch for analysis. This requirement is a new policy that has been implemented by our program since the last inspection. Mr. McGowan stated during the inspection that they would date and initial the vendor’s instruction sheet and store it with the other related documentation. Further notification of acceptable corrective action (i.e., copy of Supervisor Guidance memo to employees instructing them to document in the operator log that all PT sample preparations were performed as per vendor instructions) was received by email on 5/24/12. No further response is necessary for this finding. pH – Standard Methods, 18th Edition, 4500 H+ B Comment: The units of measure are not documented on the benchsheet. The North Carolina Administrative Code, 15A NCAC 2H .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 benchsheets 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., copy of Supervisor Guidance memo to employees instructing them to document that pH is in Standard Units on the benchsheet) was received by email on 5/24/12. No further response is necessary for this finding. Comment: Data values are reported on the Discharge Monitoring Report to 0.01 S.U., not 0.1 S.U. as required by the method. Standard Methods, 18th Edition, 4500 H+ B. (6) states: A variance of ± 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 . Notification of acceptable corrective action (i.e., copy of Supervisor Guidance memo to employees instructing them to report pH on the Discharge Monitoring Report (DMR) to 1 digit to the right of the decimal point) was received by email on 5/24/12. No further response is necessary for this finding. pH – SW-846 Method 9040 C Comment: The time of sample collection is not documented. The North Carolina Administrative Code, 15A NCAC 2H .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 benchsheets 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., copy of Supervisor Guidance memo to employees instructing them to document pH sample collection and analysis time on the sludge lime method 9040C benchsheet) was received by email on 5/24/12. No further response is necessary for this finding. Comment: Sludge samples are collected from two different tanks. The identification of those tanks was not documented. The North Carolina Administrative Code, 15A NCAC 2H .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 benchsheets 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., copy of Supervisor Guidance memo to employees instructing them to document the tank location designation on the sludge lime method 9040C benchsheet) was received by email on 5/24/12. No further response is necessary for this finding. Temperature – Standard Methods, 18th Edition, 2550 B Comment: The units of measure are not documented. The North Carolina Administrative Code, 15A NCAC 2H .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 benchsheets must provide a space for the signature or initials of the analyst, and Page 3 #5052 Progress Energy Carolinas – Brunswick Steam Electric Plant proper units of measure for all analyses. Notification of acceptable corrective action (i.e., copy of Supervisor Guidance memo to employees instructing them to document all temperature measurement units on Attachments, benchsheets, or logbooks) was received by email on 5/24/12. No further response is necessary for this finding. IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing laboratory benchsheets and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data were reviewed for December, 2011 and January and February, 2012. No transcription errors were detected. The facility appears to be doing a good job of accurately transcribing data. V. CONCLUSIONS: All findings noted during the inspection were adequately addressed prior to the completion of this report. The inspector would like to thank the staff for its assistance during the inspection and data review process. No response is required. Report prepared by: Todd Crawford Date: June 1, 2012 Report reviewed by: Jeff Adams Date: June 4, 2012