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INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #: 5237
Laboratory Name: Lumberton Power LLC
Inspection Type: Field Maintenance
Inspector Name(s): Tonja Springer
Inspection Date: June 2, 2010
Date Report Completed: June 2, 2010
Date Forwarded to Reviewer: June 7, 2010
Reviewed by: Todd Crawford
Date Review Completed: June 7, 2010
Cover Letter to use: Insp. Initial X Insp. Reg. Insp. No Finding Insp. CP
Unit Supervisor: Dana Satterwhite
Date Received: June 7, 2010
Date Forwarded to Alberta: June 9, 2010
Date Mailed: June 9, 2010
On-Site Inspection Report
LABORATORY NAME: Lumberton Power LLC
NPDES PERMIT #: NC0058301
MAILING ADDRESS: PO Box 1063
Lumberton, NC 28358
CERTIFICATE #: 5237
DATE OF INSPECTION: June 2, 2010
TYPE OF INSPECTION: Field Maintenance
AUDITOR(S): Tonja Springer
LOCAL PERSON(S) CONTACTED: Mike Houston
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:
Benchsheets are well designed, easy to follow and concise. Records are well organized and easy to
retrieve. The laboratory had implemented a standard, reagent and consumable tracking system and is
commended for being proactive in implementing new laboratory certification policy requirements.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Comment: The facility currently does not have any flow going through the plant, with the exception of
flow generated by rain fall.
Total Residual Chlorine – Standard Methods, 18th Edition, 4500 Cl G
pH – Standard Methods, 18th Edition, 4500 H+ B
A. Finding: Performance testing samples are not analyzed in the same manner as environmental
samples. The results are transferred directly to the reporting form to the vendo r and not
documented on the benchsheet.
Requirement: The analysis of performance testing (PT) samples is designed to evaluate the
entire process used to routinely report environmental analytical results. Therefore, PT samples
must be analyzed in the same manner as environmental samples. Ref: North Carolina
Wastewater/Groundwater Laboratory Certification document, Quality Assurance Policies for
Field Laboratories.
Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A
NCAC 02H .0805 (g) (1).
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#5237 Lumberton Power LLC
Comment: The laboratory has already analyzed and reported the Performance Testing (PT)
samples for the 2010 performance testing calendar year. For 2011, document the PT study
results on a benchsheet along with all other sample and quality control data.
pH – Standard Methods, 18th Edition, 4500 H+ B
Comment: The temperature sensor check is performed and the correction is posted on the meter as
required, but the process was not documented on a separate sheet of paper to be filed. The
Technical Assistance for Field Analysis of pH document states; “Document any correction that applies
on both the thermometer/meter and on a separate sheet to be filed”. A form was developed after the
inspection to document the temperature sensor check. No further response is necessary for this
finding.
Total Residual Chlorine – Standard Methods, 18th Edition, 4500 Cl G
Recommendation: Regular level PT samples may be diluted so that concentrations are within the
verified (bracketed) curve range, however, the dilution process can introduce error. It is recommended
that the facility analyze a low level Total Residual Chorine PT samples for all future PT studies. These
are currently available from many vendors.
Comment: Calibration checks, samples and the annual verification curve must be all be analyzed on
the same program.
B. Finding: Results that are below the lowest verified calibration standard concentration are
routinely being reported on the Discharge Monitoring Reports (DMR).
Requirement: The concentrations of the calibration standards must bracket the concentrations
of the samples analyzed. One of the standards must have a concentration equal to or below the
lower reporting concentration for Total Residual Chlorine. Ref: Technical Assistance for Field
Analysis of Total Residual Chlorine.
Comment: For example, if the laboratory chooses to have a lower reporting limit of 10 µg/L for
residual chlorine, the calibration curve must contain a standard at 10 μg/L. Sample results
below that concentration would be reported as < 10 µg/L.
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 NPDES permit NC0058301 for January and March, 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 and implementing the recommendation 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: Tonja Springer Date: June 4, 2010
Report reviewed by: Todd Crawford Date: June 7, 2010