#5588_06_2012_FINAL

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5588
Laboratory Name:
Southern Company — Rowan Plant
Inspection Type:
Field Initial
Inspector Name(s):
Chet Whiting,
Inspection Date:
June 21, 2012
Date Report Completed:
June 25, 2012
Date Forwarded to Reviewer: July 3, 2012
Reviewed by:
Jason Smith
Date Review Completed:
July 6, 2012
Cover Letter to use: X
Insp. Initial _ Insp. Reg. _ Insp. No Finding _ Insp. CID _Corrected
Unit Supervisor:
Gary Francies
Date Received:
7/9/12
Date Forwarded to Linda:
7/16/2012
Date Mailed:
' ( [ LQ__

Eja
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P. E. Dee Freeman
Governor Director Secretary
July 16, 2012
5588
Ms. Michelle Kroh
Southern Company — Rowan Plant
5575 NC Hwy 801
Salisbury, NC 28147
SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Initial Inspection
Dear Ms. Kroh:
Enclosed is a report for the inspection performed on June 21, 2012 by Chet Whiting. 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 electronic mail, or if you have questions or need additional information please
contact me at 828-296-4677.
Sincerely,
G c��
Gary Francies
Certification Unit Supervisor
Laboratory Section
CC: Master File
Chet Whiting
DENR DWO Laboratory Section NC Wastewater/Groundwater Laboratory Certification Branch
1623 Mail Service Center, Raleigh, North Carolina 27699-1623
Location: 4405 Reedy Creek Road. Raleigh, North Carolina 27607-6445
Phone: [phone] \ FAX: [phone] One
Internet: www.dwglab.org Nora,, Carolina.
An Equal Opportunity \ Affirmative Action Employer AaharallY

LABORATORY NAME:
NC GENERAL PERMIT #
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
INTRODUCTION:
On -Site Inspection Report
Southern Company — Rowan Plant
NCG500582
5575 NC Hwy 801
Salisbury, BC 28147
5588
June 21, 2012
Field Maintenance
Chet Whiting
Michelle Kroh
This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for
the analysis of environmental samples.
li�rl=�111=1 7_1weilIT, I�il
The laboratory is neat and well organized and has all the equipment necessary to perform the analyses.
The laboratory is not required to have North Carolina Wastewater/Groundwater certification but has
voluntarily maintained certification.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
Comment: The laboratory was not documenting pH units.. 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. a cover
statement was written in the log book stating that all pH measurements were in S.U.) was received by
email on June 7, 2012. No further response is necessary for this finding.
Comment: The laboratory needed to increase the documentation of materials and reagents. 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, manufacturer, lot number, and expiration date must be
retained for chemicals, reagents, standards and consumables used for a period of five years.

Page 2
#5588 Southern Company Plant Rowan
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 copy of a new log sheet implemented
that includes consumable traceability) was received by email on June 25, 2012. No further response
is necessary for this finding.
Comment: The laboratory was not documenting Proficiency Testing (PT) samples in the same manner
as environmental samples (i,e., on a benchsheet). Proficiency Testing Requirements, February 20,
2012, Revision 1.2. states: The analysis of PT samples is designed to evaluate the entire process used
to routinely report environmental analytical results. Therefore, PT samples must be analyzed and the
process documented in the same manner as environmental samples. Notification of acceptable
corrective action (i.e., PT samples will be documented in the same manner as environmental samples)
was received by email on June 25, 2012. No further response is necessary for this finding.
Comment: The laboratory was not documenting the preparation of PT samples. The Proficiency Testing
Requirements document, February 20, 2012, Revision 1.2 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., PT sample traceability will be documented) was received by email on June 25,
2012. No further response is necessary for this finding.
pH — Standard Methods, 18t" Edition, 4500 H+ B
Comment: pH values were reported that exceed the method specified accuracy (0.1 S.U.) for this
analysis. Standard Methods, 4500 H+ B-2000. (6) states in part: 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. Notification of acceptable
corrective action (i.e. a statement that pH results will be reported to 0.1 S.U.) was received by email on
June 25, 2012. No further response is necessary for this finding.
Total Residual Chlorine — Hach 10014 URL
Comment: The annual laboratory generated curve lowest concentration standard was not equal to or
less than the permit limit of 17 r;g/L. Approved Procedure for Field Analysis of Total Residual Chlorine
(Option 3) states: A series of 5 standard concentrations (not counting the blank) that bracket the range
of the samples to be analyzed are analyzed. The obtained values are programmed into the instrument,
computer spreadsheet, scientific calculator, or plotted manually. Sample results are obtained by
comparison to the linear regression of those values. The standard materials used must be of an
acceptable purity. Each analyst performing the test must have an individual calibration curve. This type of
curve must be performed annually (i.e., at least every 12 months). Total Residual Chlorine 50,ug/L (May
1,2008) states: "This will not change the analysis, annual verification of meter performance or data
reporting, but simply how the reported values will be evaluated by DWQ from a compliance standpoint.
Notification of acceptable corrective action (i.e. a new curve verification that includes a 10 ug/L
standard) was received by email on June 25, 2012. No further response is necessary for this
finding.
Comment: The lowest standard of the curve in use at the time of the inspection was 50 ug/L.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing field testing records to the Self Report Form. Data were reviewed
(NC General Permit # NCG500582) for April, 2012. No transcription errors were detected. The facility
appears to be doing a good job of accurately transcribing data.

Page 3
#5588 Southern Company Plant Rowan
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: Chet Whiting Date: June 25, 2012
Report reviewed by: Jason Smith Date: July 6, 2012