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Home My WebLink About#5145 11-final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: #5145 Laboratory Name: Progress Energy Carolinas – HEEC Outfall 007 Inspection Type: Field Maintenance Inspector Name(s): Jeffrey R. Adams Inspection Date: February 22, 2011 Date Report Completed: March 04, 2011 Date Forwarded to Reviewer: March 04, 2011 Reviewed by: Jason Smith Date Review Completed: March 14, 2011 Cover Letter to use: Insp. Initial X Insp. Reg. Insp. No Finding Insp. CP ___ Corrected Unit Supervisor: Dana Satterwhite Date Received: March 15, 2011 Date Forwarded to Alberta: March 16, 2011 Date Mailed: March 16, 2011 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Progress Energy Carolinas – HEEC Outfall 007 NPDES PERMIT #: NC0039586 ADDRESS: 3932 New Hill-Holleman Road New Hill, NC 27562 CERTIFICATE #: 5145 DATE OF INSPECTION: February 22, 2011 TYPE OF INSPECTION: Field Maintenance AUDITOR(S): Jeffrey R. Adams LOCAL PERSON(S) CONTACTED: Steve Cahoon and William Lohmeyer 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. Records were maintained and well organized, however, some quality control procedures need to be implemented. Performance testing samples have been analyzed for all certified parameters for the 2010 proficiency testing calendar year and the graded results were 100% acceptable. The laboratory was given a packet containing North Carolina Laboratory Certification quality control requirements and policy changes during the inspection. Finding A is a new policy that has been implemented by our program since the last inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Traceability A. Finding: The laboratory needs to increase the documentation of materials and reagents used or made in the laboratory. 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 (where specified). A system (e.g., traceable identifiers) must be in place that links standard/reagent Page 2 #5145 Progress Energy Carolinas – HEEC Outfall 007 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 primary standards, chemicals, reagents, and materials used for a period of five years. Consumable materials such as pH buffers, lots of pre-made standards and/or media, solids and bacteria filters, etc. are included in this requirement. Ref: Quality Assurance Policies for Field Laboratories. Dissolved Oxygen – Standard Methods, 18th Edition, 4500 O G Comment: The laboratory is not checking the Dissolved Oxygen (DO) temperature sensor against a National Institute of Standards and Technology (NIST) or NIST traceable thermometer annually. The Technical Assistance for Field Analysis of Dissolved Oxygen states: The temperature sensor in the meter must be checked every 12 months against an NIST certified or NIST traceable thermometer and the process documented even if the instrument is not used for reporting temperature results. The temperature correction (even if it is zero) must be posted on the meter as well as in hard copy format (to be retained for 5 years). The laboratory submitted a copy on February 24, 2011 of their temperature sensor checks. No further response is necessary for this finding. Dissolved Oxygen – Standard Methods, 18th Edition, 4500 O G pH – Standard Methods, 18th Edition, 4500 H+ B Comment: The laboratory is not posting NIST temperature corrections on the DO and pH meters. The Technical Assistance for Field Analysis of Dissolved Oxygen and Technical Assistance for Field Analysis of pH documents state: The temperature correction (even if it is zero) must be posted on the meter as well as in hard copy format (to be retained for 5 years). The laboratory submitted notification on February 24, 2011 that the NIST sensor check has been performed and the lab has posted the corrections (even if zero) on the DO and pH meters. No further response is necessary for this finding. Comment: You may have trouble getting your NIST thermometer re-certified. As part of an initiative to reduce the use of mercury in products, EPA is working with stakeholders to reduce the use of mercury-containing non-fever thermometers in industrial and commercial settings. The National Institute of Standards and Technology (NIST), which is working with EPA on this effort, announced on February 2, 2011 that it will no longer calibrate mercury-in-glass thermometers for traceability purposes beginning on March 1, 2011. Other vendors may follow this lead. Additional information on the phase-out of mercury-filled thermometers and selecting alternatives to mercury-filled thermometers can be found on the following EPA website: http://www.epa.gov/hg/thermometer.htm. pH – Standard Methods, 18th Edition, 4500 H+ B B. Finding: The laboratory is not analyzing a post calibration check following sample analysis. Page 3 #5145 Progress Energy Carolinas – HEEC Outfall 007 Requirement: If compliance samples are analyzed throughout the day, a post calibration check (e.g., 7 buffer) must be analyzed mid-day and at the end of the run (i.e., roughly every 4 hours based on an eight hour day). Calibration checks must be documented. Ref: Technical Assistance for Field Analysis of pH. IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing field testing records and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data were reviewed for Progress Energy HEEC Carolinas Outfall - 007 (NPDES permit #NC0039586) for October, November, and December, 2010. No transcription errors were detected. The facility appears to be doing a good job of accurately transcribing data. V. CONCLUSIONS: Correcting the above-cited findings will help this lab to produce quality data and meet certification requirements. The inspector would like to thank the staff for its assistance during the inspection and data review process. Please respond to all findings. Report prepared by: Jeffrey R. Adams Date: March 04, 2011 Report reviewed by: Jason Smith Date: March 14, 2011