NC0004774_Lab Inspection_20190923

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vironmentW Quality
September 20, 2019
5151
Mr. Girish C. Sharma
Duke Power Company LLC d/b/a Duke Energy Carolinas LLC - Buck
13339 Hagers Ferry Road
Bldg. 7405
Mail Code: MG03A2
Huntersville, NC 28078-7929
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Sharma:
Enclosed is a report for the inspection performed on August 21, 2019 by Michael Cumbus and Beth
Swanson. Where Findings) are cited in this report, a response is required. Within thirty days of receipt,
please supply this office with a written item for item description of how these Finding(s) were corrected.
Please describe the steps taken to prevent recurrence and include an implementation date for each
corrective action. If the Finding(s) cited in the enclosed report are not corrected, enforcement actions may
be recommended. For Certification maintenance, your laboratory must continue to carry out the
requirements set forth in 15A NCAC 2H .0800.
A copy of the laboratory's Certified Parameter List at the time of the audit is attached. This list will reflect
any changes made during the audit. 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 me at [phone] Ext. 259.
Sincerely,
Beth Swanson
Technical Assistance & Compliance Specialist
Division of Water Resources
Attachment cc: Michael Cumbus, Dana Satterwhite, Mooresville Regional Office
North Carolina Department of Environmental Quality � Division of Water Resources
1623 Mail Service Center � Raleigh, North Carolina 27699 L623
Phone [phone]jFax 91.9.733.6241.

ADDRESS: 1385 Dukeville Rd,
Salisbury, NC 28146
This laboratory was inspected by representatives 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.
II. GENERAL COMMENTS:
The facility is neat and well organized and has all the equipment necessary to perform the
analyses. Records are well organized and easy to retrieve. The laboratory has been proactive
in keeping up with updates and changes required by this Program, particularly in the area of
consumable traceability.
All required Proficiency Testing (PT) Samples have been analyzed for the 2019 PT Calendar Year
and the graded results were 100% acceptable.
Contracted analyses are performed by Shealy Environmental Services Inc. (Certification #329),
Pace Analytical Services LLC (Certification #12) and Duke Power Company LLC d/b/a Duke
Energy Carolinas LLC (Certification #248).
Approved Procedure documents for the analysis of the facility's currently certified Field
Parameters were provided at the time of the inspection.

Page 2
#111 Lab Name
Comment: The laboratory informed the auditors during the paper trail investigation that when
contract data is received with a qualifier, the letter of the qualifier was entered into the data cell of
the Discharge Monitoring Report (DMR). North Carolina Administrative Code, 15A NCAC 2H
0805 (e) (5) states: Reported data associated with quality control failures, improper sample
collection, holding time exceedances, or improper preservation shall be qualified as such. Notation
must be made in the comment section of the DMR. This would include any letter used as a data
qualifier as well as a brief description of the quality control exceedance.
Finding: The laboratory benchsheet is lacking pertinent data: Sample identification.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses and shall consist of: sample
identification. Ref: 15A NCAC 2H .0805 (g) (2) (I).
Requirement: The following must
analysis is performed: sample site
Procedure for the Analysis of pH
Analysis of Temperature,
be documented in indelible ink whenever sample
(ID or location). Ref: NC WW/GW LC Approved
and NC WW/GW LC Approved Procedure for the
Comment: The laboratory benchsheet utilized site descriptors that differed from the
permitted site ID. The downstream site noted as 002 is listed on the DMR as 007.
There is also a permitted outfall site "002", which can lead to further confusion when site
descriptors do not match the permitted site ID.
Finding: The laboratory benchsheet is lacking pertinent data: Method reference and units
of measure.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses and shall consist of: the method or
Standard Operating Procedure and the proper units of measure. Ref: 15A NCAC 2H .0805
(g) (2) (A) and (L).
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Method reference and units of measure. Ref: NC WW/GW LC
Approved Procedure for the Analysis of pH and NC WW/GW LC Approved Procedure for
the Analysis of Temperature.
Comment: pH units of measure (S.U.) were missing for the month of August.
Finding: The laboratory benchsheet is lacking pertinent data: permit number.
Requirement: The following must
analysis is performed: Facility name
Procedure for the Analysis of pH
A
nalysis of Temperature.
be documented in indelible ink whenever sample
and permit number. Ref: NC WW/GW LC Approved
an
d NC WW/GW LC Approved Procedure for the

Page 3
#111 Lab Name
Comment: The calibration of the pH meter was documented on the PT data sheet, not in the
instrument calibration log used for compliance samples.
Recommendation: It is recommended that the laboratory record the calibration of the pH
meter for PT Sample analyses in the calibration log used for routine compliance samples, and
that the time of analysis of the PT Samples be documented to ensure that analysis did not
occur prior to calibration.
®. Finding: PT Samples have not been distributed among all analysts from year to year.
Requirement: Laboratories shall also ensure that, from year to year, PT Samples are
equally distributed among personnel trained and qualified for the relevant tests and
instrumentation (when more than one instrument is used for routine Compliance Sample
analyses), that represents the routine operation of the work group at the time the PT
Sample analysis is conducted. Ref: Proficiency Testing Requirements, October 29, 2018,
Revision 3.
E. Finding: The laboratory does not report results of all tests on the characteristics of the
effluent when duplicate sample analyses are performed.
Requirement: The results of all tests on the characteristics of the effluent, including but
not limited to NPDES permit monitoring requirements, shall be reported on the monthly
report forms. Ref: 15A NCAC 213.0506 (b) (3) (J).
Comment: If the average value of multiple sample measurements is not reported, the
following convention must be followed when deciding which value to report in the daily Lou
• Any value in violation of permit limits must be reported in the daily cell. If multiple
samples yielded noncompliant results, the most extreme noncompliant value must
be reported in the daily cell.
• If all values taken during the day were compliant with the permit limits, the value
closest to the bounds of the limit range (high or low) must be reported in the daily
cell.
• The other value not reported in the daily cell must be reported in the comment
section.
Comment: The laboratory received values of 19.8 NTU and 20.5 NTU for turbidity
samples collected on July 2, 2019 from site 007, but only 19.8 NTU was entered into the
)MR.
Temperature —Standard Methods, 2550 B-2011 (Aqueous)
F. Finding: The laboratory is not verifying the compliance temperature -measuring device
every 12 months.
Requirement: All compliance temperature -measuring devices without a valid NIST
certificate must be checked initially and every 12 months against an NIST traceable
temperature -measuring device and the process documented. Documentation must include

l
the serial number of the device being checked. The serial number, stated accuracy and
expiration date of the NIST traceable temperature -measuring device used in the
comparison must also be documented. Verification data must be kept on file and be
available for inspection for 5 years. (NOTE: Vendors or other Certified laboratories may
provide assistance in meeting this requirement. When a vendor or other Certified
laboratory provides this assistance, they must provide a copy of their NIST Certificate or
the serial number, accuracy and calibration expiration date.) Ref: NC WW/GW LC
Approved Procedure for the Analysis of Temperature.
Comment: The laboratory last verified the compliance temperature -measuring device in
November 2018. Previously, the device had been verified in September 2017.
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) and contract lab reports to DMRs submitted to the North Carolina Division of Water
Resources. Data were reviewed for Duke Power Company LLC d/b/a Duke Energy Carolinas
.LC — Buck (NPDES permit # NC0004774) for May and July, 2019. The following errors were
noted:
Value on
Benchsheet
Date
Parameter
Location
Value on DMR
*Contract Lab
Data
7/2/2019
Turbidity
007
* 2065 N.T.U.
Not Reported
To avoid questions of legality, it is recommended that you contact the appropriate Regional
Office for guidance as to whether an amended DMR will be required for the JUIy 2, 2019 data.
A copy of this report will be made available to the Regional Office.
V. CONCLUSIONS:
Correcting the above -cited Findings and implementing the Recommendations will help this
laboratory to produce quality data and meet Certification requirements. The inspector would like
to thank the staff for their assistance during the inspection and data review process. Please
respond to all Findings and include supporting documentation, implementation dates
and steps taken to prevent recurrence for each corrective action.
Report prepared by: Michael Cumbus Date: September 6, 2019
Report reviewed by: Tom Halvosa Date: September 18, 2019